WI0400045_Permit Application_20030212

Duracell/Gillette
305 New Hwy 64 East
Lexington, NC 27292
Application for Permit to
Construct and/or Use a Well(s)
for Injection
Class 51 Wells
February 2003
Environmental Resources Management

NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
APPLICATION FOR PERMIT TO CONSTRUCT AND/OR
USE A WELL(S) FOR
INJECTION
Class 5I Wells
In Accordance with the provisions of NCAC Title 15A: 02C.0200
Complete application and mail to address on the back page.
TO: DIRECTOR, NORTH CAROLINA DIVISION OF WATER QUALITY
DATE: February 12, 20 03
A. PERMIT APPLICANT
Name: Duracell/Gillette
Address: 305 New Hwy 64 East
City: Lexington State: NC Zip Code: 27292
County: Davidson Telephone: [phone]
C. PROPERTY OWNER (if different from applicant)
C=
Name: w
Address: rn
City: State: Zip Code:
County: Telephone:
C. STATUS OF APPLICANT
S-'
Private: X Commercial: Federal: State: r1a -' m
County: Municipal: Native American Lands: —
D. FACILITY (SITE) DATA
(Fill out ONLY if the Status is Federal, State, County, Municipal or Commercial).
Name of Business or Facility:
Address:
City: Zip Code: County:
Telephone: Contact Person:
E. INJECTION PROCEDURE
Provide a detailed description of all planned activities relating to the proposed
injection facility including but not limited to:
(1) construction plans and materials;
(2) operation procedures; and
(3) a planned injection schedule.
GW-57 REM (Jan, 2000) Page 1 of 18

Response: A remedial project intended to mitigate ground water and soil
contamination at the Gillette/Duracell facility located in Lexington, North
Carolina is ongoing. One objective of this project is to remediate certain soils in
three small areas down to the top of the shallow ground water using in -situ
chemical oxidation. These three areas to be remediated using in -situ chemical
oxidation were impacted by a release of chlorinated solvents that occurred from
the 1960s through the 1970s on the Gillette/Duracell facility located in
Lexington, North Carolina. This remediation activity is being conducted as part
of the Remedial Design (RD) and Remedial Action (RA) implementation for the
Site pursuant to a Unilateral Administrative Order (UAO) issued by U.S. EPA
under CERCLA. The NCDENR has been actively involved in this project from
its inception.
One part of the overall remedial approach for the Gillette/ Duracell site is to
apply the technology of in -situ chemical oxidation to certain small areas of on -
site soils. This technology is proposed for implementation per this application.
The three areas for which in -situ chemical oxidation will be used are identified in
Figure 1.
For this Site, it is being proposed that sodium or potassium permanganate be
used as the oxidizing agent. The cations, potassium and sodium have no effect
on the oxidizing power of the permanganate. Potassium permanganate is
generally the preferred form because of its lower cost. However, sodium may be
used if the applied concentration of permanganate is above 4%. Concentrations
of potassium permanganate higher than 4% are not possible due to the limited
water solubility of the potassium form.
There are many oxidants that are potentially usable. Permanganate was selected
because it is stable, non -hazardous (outside of its oxidizing nature) and easily
handled. It is widely used as a safer alternative to chlorine in conventional
water treatment. Permanganate reacts to oxidize PCE, TCE, and DCE. This
reaction is rapid and complete. These reactions are given below:
PCE: 4KMnO4 + 3C2C14 + 4H204 4MnO2 + 6CO2 + 12C1- + 4K+ + 8H+
TCE: 2KMnO4 + C2HC13 4 2MnO2 + 2CO2 + 3C1- + 2K+ + H+
DCE: 8KMnO4 + 3C2H2C12 4 8MnO2 + 6CO2 + 6C1- + 8K+ + 2OH- + 2H2O
Laboratory (bench -scale) treatability tests were performed using site soils and
ground water to confirm the effectiveness of this oxidizer in meeting the
remedial objectives for this Site. The tests also estimated the likely dosage
required to achieve the desired reductions in the adsorbed and dissolved phase
chlorinated solvent concentrations. The Laboratory Treatability Study Report is
included as Attachment A.
GW-57 REM (Jan, 2000) Page 2 of 18

The proposed method of delivery of permanganate is by diluting the sodium
permanganate solution and application of the dilute solution through temporary
Geoprobe points. This method allows for efficient distribution of the oxidizer to
the target treatment zones. Based on the laboratory treatability test and the most
recent contaminant distribution, as determined, from soil and ground water
sampling, the proposed treatment plan was developed and is presented below:
Item (1): Construction Methods and Materials:
The application of the chemical oxidant will utilize direct injection through
temporary Geoprobe points. As such, there will be no construction activities.
The permanganate injection solution will be made up in batches using a 300-
gallon polyethylene tank. Each batch will consist of 250 gallons of water and 20
gallons of 40% sodium permanganate. This will yield a 4 to 4.5% solution of
sodium permanganate. The diluted permanganate will be pumped from the
tank to the Geoprobe point and directly injected into the subsurface.
Item (2): Operation Procedures:
The operational procedures to be employed are as follows:
1. Make up 250-gallon batch of permanganate (250 gallons of water with 20
gallons of 40% sodium permanganate as discussed above).
2. Set up Geoprobe rig with injection tip at initial injection point location.
Advance injection tip to first 2.5' injection interval. The first treatment
interval will be determined based on documented depth of COCs at each
specific injection location.
3. Inject approximately 80 gallons of permanganate solution.
4. Advance injection tip to the second 2.5-foot injection interval. The second
treatment interval will be determined based on documented depth of
COCs at each specific injection location.
5. Inject approximately 80 gallons of permanganate solution.
6. Continue injection at 2.5-foot injection intervals until the injection process
is complete for the injection point. The total treatment interval will be
determined based on the documented depth of COCs at each specific
injection location.
7. Withdraw injection point from hole.
8. Grout hole to ground surface using a cement/bentonite grout.
9. Move Geoprobe rig to next injection point location.
10. Repeat steps 2-9 at next three injection point locations.
11. Make up another 250-gallon batch of permanganate solution.
12. Continue preceding steps until all injection point locations are completed.
GW-57 REM (Jan, 2000) Page 3 of 18

Item (3): Planned Injection Schedule:
It is currently planned that a total of 51 points on 10-foot centers will be required
for the injection operations (reference Figure 1). The final number and locations
of the injection points may vary somewhat based on site conditions. It is
estimated that three injection points can be completed per day. Each point will
have two, 2.5-foot injection intervals. Each interval will receive 80 gallons of
permanganate solution. Treatment of three injection points will require two
batches of permanganate per day. Approximately 19 days of Geoprobe work
will be required to treat the area.
F. DESCRIPTION OF SITE
Provide a brief description of the contamination incident and the incident
number assigned by the Division of Water Quality staff in the Department's
Regional Office:
Response: The Duracell Battery Tech (Lexington, North Carolina Plant) Site
consists of approximately 145 acres that includes 27.5 acres on which batteries
have been manufactured since the early 1960s, an additional 17.5 undeveloped
acres (former Cecil property) that were acquired by Duracell, and approximately
100 undeveloped acres (former Swing property) in which Duracell obtained a
property interest and that subsequently were acquired by Duracell (reference
Figure 2). The use of the terms "on -site" and "off -site" in this report are made in
the context of the actual operating facility property (27.5+/- acres) and does not
include the property to the north and east of the operating facility property that
also is owned by Duracell.
The Site is located at 305 New Highway 64 East, Lexington, Davidson County,
North Carolina. The coordinates for the facility are latitude 35' 49' 56" and
longitude 80' 13' 59". The Site location has been designated on the Lexington
East, U.S. Geological Survey (USGS) topographic map attached as Figure 2.
The Site currently consists of three plant buildings (reference Figure 3). In the
late 1950s, the property encompassing Plant #1, former Plant #2, and Building #4
was purchased from the Swing family. Prior to plant construction, the property
was a farm. The Duracell -Lexington facility has been owned previously by
Duracell U.S.A. and is currently owned by the Gillette Company. Plant #3
building and property were purchased in the 1970s. Prior to purchase, the
building was an Ames Department Store. Building #4 was added in the 1960s.
The Duracell -Lexington, North Carolina facility has manufactured batteries since
the early 1960s. In the 1960s, P.R. Mallory operations had several military
contracts to manufacture mercuric oxide batteries. Initially, the cells were
assembled into batteries and shipped at Plant #1. After the purchase of Plant #3,
storage and shipping was conducted there. The original construction of Plant #1
was from the aisle area south of the current production area to the south (toward
the main offices). The manufacturing area of Plant #1 was added in the mid-
1960s. In addition, Plant #2 was added to the northwest of Plant #1 in 1967.
GW-57 REM (Jan, 2000) Page 4 of 18

Plant #3 was originally used for sub -assembly operations with an advanced
engineering design section up until the late 1970s. Some special battery
assembly was conducted in Plant #3 for custom one-time batteries and for
military shipping. In 1994, an addition was built on the west side of Plant #3.
Also in 1994, the Memtek treatment system was moved from Plant #2 to the
center bay of Building #4. Two wastewater tanks were added to the east side of
Building #4 to temporarily store process wastewater and recovered ground
water prior to treatment. Plant #2 was demolished in late 1994.
All tooling for battery assembly was made in the machine shop located on the
north side of Plant #1. All tools, dyes, and presses needed to be cleaned as part
of routine maintenance. They were cleaned with various solvents. In addition,
the watch battery cells were specially cleaned in a solvent washer. The specific
cleaning chemicals used at the facility included:
• tetrachloroethene
• trichloroethene
• methylene chloride
• 1,1,1-trichloroethane
• 1,1,2-trichloroethane
• acetone
Until 1980, all spent solvents were disposed of in a gravel pit (former solvent
disposal area) located north of Plant #1 and south of Building #4. The exact
construction details of the pit and specific disposal practices are unknown.
G. HYDROGEOLOGIC DESCRIPTION
SECTION (G) MUST BE ORIGINALLY SEALED AND SIGNED BY A
LICENSED GEOLOGIST
Provide a hydrogeologic description, soils description, and cross section of the
subsurface to a depth that included the known or projected depth of
contamination. The number of borings shall be sufficient to determine the
following:
(1) the regional geologic setting;
(2) significant changes in lithology;
(3) the hydraulic conductivity of the saturated zone;
(4) the depth to the mean seasonal high water table; and
(5) a determination of transmissivity and specific yield of the aquifer to be
used for injection (showing calculations).
Response: The following information is provided regarding the regional and;site-
specific geologic and hydrogeologic conditions:
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GW-57 REM (Jan, 2000) Page 5 of 18

Site Soil and Geology
Regional Soils
The soil survey of Davidson County, North Carolina (USDA, 1994) reports that
the soil in the county is generally weathered from felsic, intermediate, and mafic
crystalline rocks or from fine-grained metamorphic rocks. The crystalline rocks
are primarily in the northern and northwestern parts of the county. The fine-
grained metamorphic rocks are in the southern and southeastern parts of the
county. The felsic rocks are mostly granite, gneiss, or schist. Soils that are
formed in material weathered from this type of rock are acidic. The mafic rocks
are mostly gabbro. Soils that formed in material weathered from this type of
rock are slightly acidic to mildly alkaline. Large areas of the county are
underlain by intermediate rocks, such as diorite, or have a mixture of felsic and
mafic rocks. The fine-grained metamorphic rocks are slate -like rocks that are
dominantly argillite. Soils formed in material weathered from these rocks are
acidic. Soil textures vary depending on the mineralogy or the parent material
(e.g. the schists produce micaceous silts while gneiss or intrusives produce silty
or sandy clays).
Local Soils
The soil beneath the Site generally consists of weathered bedrock or saprolite,
which is composed of predominantly silty clays to clayey silts. Based on prior
investigative efforts, two distinct soil types were noted to be present in the
shallow subsurface beneath the Site. The uppermost soil zone encountered at the
Site is a medium consistency, multicolored (red, orange, yellow, brown, gray and
green) silty clay. The silt fraction in this zone ranged from approximately 10%
near the ground surface to approximately 30% near the base. Some medium- to
fine-grained sand was present in this zone. This uppermost zone was found to
extend from the ground surface to a depth of approximately five to ten feet
below ground level (BGL).
Beneath this uppermost zone, the residual materials generally grade downward
to a medium consistency, mottled red -orange and brown -black clayey silt. The
clay proportion in this zone generally ranged from approximately 30% to 40%.
Remnant foliations, indicative of the parent bedrock material, and minor fine
sand were noted to be present in this zone. The appearance of the residual soil is
typical of saprolite in the Piedmont region of North Carolina, with grain size
increasing and degree of weathering decreasing with depth. There are no
significant changes in the lithology of the local soils that would have a significant
effect on the proposed injection system.
Regional Geology
Davidson County is in the center of the Piedmont physiographic province.
Davidson County is on the boundary between two major geologic belts, the
GW-57 REM (Jan, 2000) Page 6 of 18

Charlotte Belt to the north and the Carolina Slate Belt to the south (Carpenter,
1982). The Charlotte belt is characterized by both felsic and mafic igneous rocks.
The felsic rocks are primarily granite, and the mafic rocks are primarily gabbro.
The Carolina Slate Belt includes various types of volcanic and sedimentary rocks,
such as mudstones, and mixtures of volcanic debris. The felsic volcanic rocks are
very resistant to weathering and underlie the more prominent topographic
features. The sedimentary rocks consist of such rocks as mudstones and
siltstones that have been physically and chemically altered by metamorphism to
a more indurated slate. Much of the sedimentary rock is intermediate in
hardness and is classified as argillite.
Local Geology
The fractured bedrock at the Site consists primarily of the felsic intrusive
complex on the west side of the facility and intermediate intrusive rocks on the
east side of the facility (Carpenter,1982). Alluvium is found to the north along
the unnamed tributary to Leonards Creek. The felsic intrusive complex consists
of white to gray, fine to coarse -grained, massive to foliated, metamorphosed
bodies of varying assemblages of intimately associated felsic intrusive rock types.
The complex includes mineralogical gradations within a single body in some
areas while in other areas it includes separate intrusions. Rock types include
granite, granodiorite, quartz, diorite, and quartz monzonite. Primary minerals
include quartz, plagioclase, potassium feldspar, muscovite, biotite, chlorite,
epidote and sericite. Intermediate intrusive rocks consist of dark, greenish -gray
to black, medium -to -coarse grained, massive, wellJointed metamorphosed
bodies, probably dioritic in composition. Primary minerals include hornblende,
plagioclase, biotite, epidote, chlorite, magnetite, and minor quartz. Alluvium is
dark brown, gray to white unconsolidated sand, silt, and clay, occasionally
containing subrounded to well-rounded pebbles and cobbles.
Site Hydrogeology
Ground water in the general vicinity of the Site exists within two zones. The first
or uppermost, water -bearing zone is within the silty clay residual saprolite soils
overlying felsic igneous bedrock. The second, or lower, water -bearing zone is
within the underlying igneous bedrock where the occurrence and movement of
ground water is controlled by secondary openings such as fractures, joints, and
foliations. Due to gradational changes from weathered saprolite to competent
bedrock, ground water in the uppermost water -bearing zone is expected to show
preferential movement along relic structures. Ground water in the saprolite is
usually found under unconfined or semi -confined conditions with ground water
flow generally conforming to surface topography. Due to the low permeability
of the fine-grained materials comprising the uppermost water -bearing zone,
ground water yields to wells tapping this zone are very small and typically not
sufficient for water supply purposes.
GW-57 REM (Jan, 2000) Page 7 of 18

Ground water in the lower water -bearing zone in bedrock is typically under
semi -confined or confined conditions with flow direction being controlled by the
presence and orientation of secondary openings. Overall ground water
movement will be from areas of higher hydraulic head (higher elevations)
toward areas of lower hydraulic head (lower elevations or stream valleys).
Ground water yields from the bedrock are typically higher than the upper zone
above bedrock with yields high enough to sustain private water supplies.
Private water wells tapping the bedrock aquifer and the shallower saprolite zone
are present in the general vicinity of the Site (reference Section K).
As a result of extensive on -site ground water investigative activities that have
been conducted at the Site to date, there is detailed documentation on the
hydrogeologic conditions at the Site. The initial ground water investigation at
the Site was conducted in 1981, which was followed by a series of supplemental
investigations (including the RI activities) that ultimately resulted in the
installation of a total of 93 ground water monitoring wells at the Site, as well as
13 shallow recovery wells and four deep recovery wells. The locations of these
wells are shown in Figure 4. At this time, 87 monitoring wells and 12 shallow
recovery wells, in addition to the four deep recovery wells, are present at the
Site. Wells MW-13, MW-14, MW-19, MW-21, MW-22 and SR-4 were closed and
abandoned during previous soil removal activities. In addition, MW-24 was
closed and abandoned as part of the 1997 Phase II RI activities.
Shallow Aquifer
The ground water system at the Site is characterized by an interconnected upper
water -bearing zone in the weathered, unconsolidated saprolite and a lower
water -bearing zone in the igneous bedrock. The upper water -bearing zone is
comprised of an upper layer of predominantly brown, clayey silt with some sand
which is underlain by a less weathered layer of primarily tan to brown, silty sand
(saprolite). This lower layer shows a gradational change to more competent
bedrock with depth. The depth to bedrock has been found to range from about 8
ft to as much as approximately 76 ft. Depth to ground water in this upper water -
bearing zone typically ranges from four to 32 ft depending on the location at the
Site and the time of year. Representative cross -sectional profiles, including pre -
RI monitoring well screen intervals, of the shallow ground water system in the
northern site area are provided in Figures 5 and 6. The locations of these cross -
sectional profiles are depicted in Figure 7. Figures 8 through 11 are
representative cross -sectional profiles for the entire Duracell -Lexington Site
based on the hydrogeologic information obtained from the pre -RI and RI
monitoring wells. The locations of these profiles are depicted in Figure 12. There
are no significant changes in the lithology of the shallow aquifer that would have
a significant effect on the proposed injection system.
GW-57 REM (Jan, 2000) Page 8 of 18

Bedrock Aquifer
The deeper water -bearing zone in the underlying igneous bedrock is somewhat
less characterized than the shallow zone with a total of 40 monitoring/recovery
wells tapping this zone. As indicated previously, the bedrock is comprised
primarily of felsic intrusive and intermediate intrusive rock, which has been
fractured and jointed, as well as having a foliated structure. The occurrence and
movement of ground water in the bedrock is controlled by the distribution and
degree of interconnection~ of these secondary openings (fractures and joints).
Depth to ground water in the bedrock zone varies considerably due to the
random distribution of openings; however, static water levels in the bedrock
wells typically range from four to 30 ft depending on the location at the Site and
the time of year.
Shallow Ground Water Movement
Ground water flow in the upper water -bearing zone has been well defined over
the last several years due to the large number of on -site monitoring wells. A
total of 64 shallow saprolite monitor/recovery wells are currently present on -
site. A ground water flow map based on water level data from non -pumping
conditions on May 2000 is provided in Figure 13. A ground water divide was
identified near the central portion of the Duracell -Lexington Plant property. The
overall direction of ground water flow on the northern portion of the Site is
generally to the north, which conforms to the original topography of the area and
coincides with a structural bedrock low as evidenced in Figure 6. Historically,
the overall direction of ground water flow has not changed significantly in this
area even though seasonal fluctuations in water levels have been routinely
documented. Based on the topographic setting, data from temporary off -site
monitoring wells, and ground water elevation data from permanent off -site
monitoring wells, ground water in this uppermost water -bearing zone is
expected to move to the north from the Site and ultimately discharge to the small
unnamed tributaries (T1 and T2) to Fritz Branch, which in turn discharges to
Leonards Creek (reference Figure 2).
The ground water elevation data obtained during the Phase I and Phase II RI
activities conducted at the Site indicated the overall direction of ground water
flow along the southern portion of the Site to be to the south which conforms to
the topography of the area and coincides with a structural bedrock low as
evidenced in Figure 6. The overall direction of ground water flow has not
changed significantly in this area even though seasonal fluctuations in water
levels have been documented. Based on the topographic setting and ground
water elevation data from permanent on -site monitoring wells, ground water in
this uppermost water -bearing zone is expected to move to the south from the Site
and ultimately discharge to the small -unnamed tributaries located south of the
Site.
GW-57 REM (Jan, 2000) Page 9 of 18

The ground water elevation data obtained from on -site well, MW-34, located
near the northeast property boundary adjacent to Plant #3, indicate the overall
direction of ground water flow in this area to be to the east/northeast. Based on
the topographic setting and ground water elevation data from the on -site
monitoring wells, ground water in this upper most water -bearing zone is
expected to move to the east/northeast from the Site and ultimately discharge to
the small, unnamed tributaries (T2 and T3) to Leonards Creek.
For the area in the immediate vicinity of the proposed injection system, shallow
ground water movement is toward the north with ultimate discharge of shallow
ground water being to the upper unnamed tributary to Fritz branch and Fritz
branch.
Bedrock Ground Water Movement
As discussed previously, ground water movement in the deeper bedrock system
is controlled by secondary openings (e.g., joints, fractures, and foliation
orientations) in the underlying igneous intrusive bedrock. Based on field
observations, review of aerial photographs, and logs of borings/wells at the Site,
a dominant regional pattern of structural features (lineaments) was not observed.
However, there does appear to be a significant structural lineament trending
approximately N 15°-20° E across the Site which is strongly influencing ground
water flow in the bedrock zone. Due to the intrusive nature of the bedrock in the
area, discontinuous lineaments and arcuate fracture traces would be expected
along contacts of intrusive bedrock units.
Movement of ground water in the deeper bedrock water -bearing zone has been
found to generally conform to movement in the shallow zone with the exception
of the east/northeast component of flow in the area north of the Site. A ground
water flow map based on water level data from non -pumping (ground water
recovery system not operating) conditions on May 2000 is provided in Figure 14.
Consistent with the shallow ground water, the absolute ground water elevations
varied slightly in the deeper bedrock aquifer; however, the ground water flow
patterns were almost identical for the different survey periods. A ground water
divide was identified in the deeper bedrock zone near the central portion of the
Duracell -Lexington property near Plant #1. Water level data from the deep
monitoring wells in the northern portion of the Site show an overall northerly
component of flow with monitoring/recovery wells DR-1, DR-2, and DR-3
showing consistently higher water levels than well DR-4. These water level data
also have shown a downward component of flow from the shallow saprolite
zone at DR-1, as well as at DR-3 and DR-4; however, well DR-2 has shown a
consistent upward component of flow. It is expected that ground water in the
deeper bedrock zone to the north of the ground water divide will move generally
to the north/northeast from the Site and ultimately discharge to Abbotts or
Leonards Creek. Ground water in the deeper bedrock zone to the south of the
GW-57 REM (Jan, 2000) Page 10 of 18

ground water divide will move to the south/southeast from the Site and
ultimately discharge to Abbotts Creek.
Since the proposed injection system will be restricted to the shallow soils at the
Site, the bedrock ground water system should not be affected by the system.
Hydraulic Conductivity
The results of slug tests conducted for wells in the shallow saprolite water -
bearing zone indicated a range of hydraulic conductivity values of 0.37 ft/day to
4.6 ft/day (Remedial Investigation Report Operable Unit Two, 2001). This range
of hydraulic conductivity values is very similar to the range of values developed
for the Bypass 601 Superfund site that is located in a similar hydrogeologic
environment.
The results of slug tests and pump tests conducted for wells in the deeper
bedrock water -bearing zone indicated a range of hydraulic conductivity values
of 0.06 to 2.74 ft/day based on the slug test results and a range of 0.008 to
0.37 ft/day based on pump test results. The results of the pump tests were one
to two orders of magnitude lower than the results of the slug tests for the same
wells, and are believed to be more representative of the aquifer as a whole. The
results of the slug tests are believed to represent more localized conditions and
the sand pack surrounding the well. These ranges are in the low end range of
literature values for fractured igneous and metamorphic rock (Freeze and
Cherry,1979) but are similar to range of values developed for the Bypass 601 Site
that is located in a similar hydrogeologic environment.
Depth to Mean Seasonally High Water Table
The mean depth to the water table in the immediate vicinity of the proposed
injection area is approximately 21.7 feet below ground surface (BGS). This is
based on 10 separate water level measurement from monitoring well SR-6. The
highest measured water level in this well was 20.76 feet BGS.
Transmissivity and Specific Yield
As noted above, the range of hydraulic conductivity values for the shallow,
saprolite ground water was 0.37 ft/day to 4.6 ft/day. Based on an average
saturated thickness of 10 feet of the saprolite zone in the immediate vicinity of
the proposed injection system (well SR-6), the transmissivity would be in the
range of 3.7 ft2/ day to 46 ft2/ day based on the following equation:
where:
T=Kb
K = hydraulic conductivity
b = saturated thickness
GW-57 REM (Jan, 2000) Page 11 of 18

H
The specific yield is expected to be in the range of 10 to 15 % based on the
materials comprising the saprolite zone.
MONITORING PROCEDURE
Provide plans for proposed location and construction details of ground water
monitoring well network, including a schedule for sampling and analytical
methods. Include any modeling/testing performed to investigate injectant's
potential or susceptibility to change (biological, chemical or physical) in the
subsurface.
Response: As part of the monitoring plan, the existing ground water
monitoring/recovery well SR-6 will be utilized to provide ground water quality
data. Due to the distance of other existing shallow monitoring wells from the
area to be remediated, two temporary well points will be installed immediately
adjacent to the remediation area to provide additional ground water quality data.
A site map showing the proposed monitoring well network is attached as
Figure 15.
Prior to and one month subsequent to the completion of the initial oxidant
application, ground water samples will be collected from the existing recovery
well SR-6 and the two temporary wells. These ground water samples will be
analyzed for volatile organic compounds by CLP SOW OLM04.2, soluble
manganese (by CLP SOW ILM04.1, chloride by EPA Method 325), sodium (by
CLP SOW ILM04.1), total suspended solids (by EPA Method 160.2), and color (by
EPA Method 110). In addition, the following field parameters will be measured
for each sample: pH, temperature, conductivity, oxidation-reduction potential,
and dissolved oxygen.
Bench -scale testing was performed to observe the effects of the permanganate
application on the residual soils and ground water, and to monitor the site -
specific end products of the reaction. The permanganate solution was found to
react completely with the chlorinated ethenes and other oxidizable compounds
(such as metals or other organics) present in the soils and ground water. A copy
of the Treatability Study Report is included in Attachment A.
WELL USE: Will the injection well(s) also be used as the supply well(s) for the
following?
(1) The injection operation?
(2) Personal consumption?
YES NO X
YES NO X
Response: Ground water will not be extracted from the subsurface as part of the
in -situ oxidation process and, therefore, there will be no influent line used in the
injection process. Water required for mixing/diluting the solution will be
acquired from the City of Lexington Public Works Department. Gate valves,
pressure gauges, and a flow meter will be installed on the "effluent" or
application line to control the quantity and rate of the solution applications.
Since ground water recovery will not be part of the process, there will not be a
GW-57 REM (Jan, 2000) Page 12 of 18

"Source Well". Therefore, construction details for a "Source Well" are not
applicable.
CONSTRUCTION DATA (check one)
EXISTING WELL being proposed for use as an injection well. Provide
the data in (1) through (7) below to the best of your knowledge. Attach
a copy of Form GW-1 (Well Construction Record) if available.
X PROPOSED WELL to be constructed for use as an injection well.
Provide the data in (1) through (7) below as PROPOSED construction
specifications. Submit Form GW-1 after construction.
(1) Well Drilling Contractor's Name:
NC Contractor Certification number:
(2) Date to be constructed:
Number of borings:
Approximate depth of each boring (feet):
(3) Well casing:
Type: Galvanized steel Black steel
Casing depth: From to _
Casing extends above ground
(4) Grout:
_ Plastic Other (specify)
ft. (reference to land surface)
inches
Grout type: Cement Bentonite Other (specify)
Grouted surface and grout depth (reference to land surface):
around closed loop piping; from to (feet).
around well casing; from to (feet).
(5) Screens
Depth: From to feet below ground surface.
(6) N.C. State Regulations (Title 15A NCAC 2C .0200) require the permittee to
make provisions for monitoring wellhead processes. A faucet on both
influent (recovered groundwater) and effluent (fluid being injected into the
well) lines is generally required.
Will there be a faucet on the influent line? yes no
Will there be a faucet on the effluent line? yes no
(7) SOURCE WELL CONSTRUCTION INFORMATION (if different from
injection well). Attach a copy of Form GW-1 (Well Construction Record).
If Form GW-1 is not available, provide the data in part G of this
application form to the best of your knowledge.
GW-57 REM (Jan, 2000) Paje 13 of 18

M
L.
NOTE: THE WELL DRILLING CONTRACTOR CAN SUPPLY THE DATA FOR
EITHER EXISTING OR PROPOSED WELLS IF THIS INFORMATION IS
UNAVAILABLE BY OTHER MEANS.
Response: The initial application event is scheduled to be performed during June
or July of 2003 and should be completed within a one week time period. The
oxidant will be injected into the subsurface using Geoprobe points. Each
Geoprobe point will be 1.25 inch in diameter and installed to various depths
below ground surface depending on depths of the VOCs identified in soils. An
illustration of the application tip on the Geoprobe is included as Figure 16. Each
Geoprobe point will be grouted to the surface with a bentonite/ grout slurry
(abandoned) after the application has been completed at a particular point. Table
1 gives an estimate of the areas to be treated. Table 2 provides an estimate of the
concentration of permanganate to be used and the volume to be injected at each
interval for each point.
A second application of permanganate may be applied within selected areas
based on sampling results post application. A second application will be used if
the VOCs are elevated and there is no residual permanganate present. The
second application will also use Geoprobe injection and will follow the protocol
used for the first application.
OTHER WELL DATA
Provide a tabulation of data on all wells within 1/4 mile of the injection well(s),
excepting water supply wells serving a single-family residence, which penetrate
the proposed injection zone. Such data shall include a description of each well's
type, depth, record of abandonment or completion, and additional information
the Director may require.
Response: Attached Table 3 is a construction summary of the previous
permanent monitoring wells installed at the Site and off -site to date in the
shallow saprolite zone in which injection will occur. A summary of historic
laboratory analytical results for these shallow ground water wells is included in
Tables 4 and 5.
PROPOSED OPERATING DATA
(1)
(2)
(3)
(4)
(5)
(6)
(7)
Injection rate: Average (daily)
Injection volume: Average (daily)
Injection pressure: Average (daily)
Injection temperature: Average (January)
Hydraulic capacity of the well:
gallons per minute (gpm)
gallons per day (gpd)
pounds/square inch (psi)
_° F, Average (July)
Expected lifetime of the injection facility: years
Give a description of how the above data will be measured and
controlled:
OF
GW-57 REM (Jan, 2000) Paue 14 of 18

4393INJECT DURCELI MLW 1-23-03
Push Tool Injection
Injection Tip Detail
Sequential Injection
i .25-inch Drive Stem
9
Upper Follow Packer
12•inches
i
Pertorated Drive
Stem
i
?flinches
10-Slot Continuous
1Nh+e Wound Screen
Drive Poiw
3-inches
Environmental
GEOPROBE INJECTION TIP DETAIL
FIGURE
Resources
DURACELL, U.S.A.
16
ERM Management
LEXINGTON, NORTH CAROLINA

Table l Distribution of VOCs and Their Mass in the Former Solvent Disposal Area
Duracell U.S.A., Lexington, North Carolina
Boring
Location
Length
Represented
(ft)
Width
Represented
(ft)
Area
Depth of
Contaminated
Zone (ft)
Volume
in cubic
feet
Volume of
Location (cu. Methylene
Ft.) Chloride
Concentration (mg/kg)
1,2-DCA PCE TCE
Carbon
Tetra
Mass of
1,1,2-TCA 1,1,1-TCA 1,2-DCE VOC (lbs)
287
16.5
12
198
5
54000
990
1
0.12
280
18
18
324
4
70691
1296
0.6
0.09
285
15
15
225
5
61364
1125
1
0.05
0.14
278
15
18
270
4.5
66273
1215
41
0.8
15
0.85 91 21.70
278
15
18
270
6.5
95727
1755
0.9
0.19
278
15
18
270
5
73636
1350
9.9
0.5
0.9
0.5 1.91
289
30
12
360
5
98182
1800
1.1
0.24
291
8
9
72
5
19636
360
21
4.7
1.2
1.16
273
18
18
324
5
88364
1620
0.9
0.5
0.8
2.4 0.90
273
18
M
3?4
r
8834n
1 41)(1
'1 n
I A
3.19
293
18
12
216
5
58909
1080
1.8
1.9
15
2.9
2-80
274
15
18
270
5
73636
1350
1.4
0-23
274
15
18
270
5
73636
1350
2.1
5.1
1.5
1.41
Mass of VOC (lbs) 0.02 0.01 0.17 0.11 0.06 0.00 0-24 0.01 0.62
Total Area in locations (sq. ft.) 3393
Total volume in locations (cu. Ft.) 16911 Total VOC in pounds 34.09
Assumes the density of soil is 120 pounds per cubic foot
Pounds VOC=Length (ft) x width (ft) x depth (ft) x 120 (lbs/ft3) x [VOC conc] (mg/kg) / 22 (lbs/kg) / 454,000 (mg/lb)
P:\4393\PERMITTING\OU-1 Chem Oa Injection estu to 12-19-02As - 2/3/2003

Table 2 Estimates of Chemical Oxidant Injection System
Duracell U.S.A., Lexington, North Carolina
Area to be treated, ft2
Depth to Interval to be treated, ft.
Total length of Interval to be treated, ft.
individual Treatment Interval, ft.
Injection Radius, ft.
Overlap between points, % (<50)
Porosity, %
Volume injected per treatment interval, gal
Injection rate per interval, GPM
Push rate, min/ft
Time to set treatment interval, min
Number of points used simultaneously per Rig
Hours worked per day
Number of Push Rigs Used
Oxidant Demand, lb/yd3
)r Cost $/hr
aber of Laborers for injection
IOxidant Equivalent Weight, g/eq
Contaminant Equivalent Weight, g/ eq
Contaminant Concentration, mg/Kg
Soil Bulk Density, Lb/ft3
1
5
2.5
5
0
30
80
1
2
25
1
52.
0I2
Total Number of injection Points
Injections per point
Total Number of Injections
Total. Gallons injected
Single Pore Volume, gal
Number of pore volumes injected
Time to set single injection points, hrs
Time to inject all points, hrs
Injection Pump Total Flow, gpm
Total Push Rig Time, hrs
Days of Push Rig use
Number of points per day
otal Oxidant Demand, Lbs
ixidant Concentration, %
511
102
8,160
38,148
0.21
11
191 2.7
2,340
1\�.\OU-I Cem O:!, e-ti nesnmx[e 12-119-0l-,JsT 2-2,3:2003

Table 3 Summary of Well Construction Data for Ground Water Monitoring Wells
Duracell U.SA, Lexington, North Carolina
Well
Number
Date
Installed
1Top
of Casing Casing
Elevation Stick-up
(ft-MSL"2) (ft-agl)
Total
Depth
(ft-bglh
Screened
Internal
(ft-bgl)
Sand Pack
Interval
(ft-bgl)
Screen/Casing
Material
MW-1
6/16/81
752.67 12.30
27
19-22.5
16-24
PVC/PVC
MW-2
6/17/81
734.14 Iflush
20
14-18
11-19
PVC/PVC
MW-3
6/18/81
737.13 2.50
40
33-36.5
30-38
PVC/PVC
MW4
6/18/81
748.30 2.53
54
34-38
3141
PVC/PVC
MW-5
1/20/82
745.46 2.50
30
18-28
16-28
PVC/PVC
MW-6
1/21/82
758.35 2.36
33
22-32
19-32
PVC/PVC
MW-7
1/22/82
747.38 3.27
43
33-43
18-43
PVC/PVC
MW-8
1/26/82
748.10 12.44
27
22-27
19.5-27
PVC/PVC
MW-9
1/27/82
750.96 1.24
40
29.5-39.5
23.8-39.5
PVC/PVC
MW-10
1/28/82
742.68 170
35
24-34
21-34
PVC/PVC
MW-ll
1/28/82
737.02 2.43
25
14.5-24.5
12.5-24.5
PVC/PVC
MW-12
1/29/82
737.15 2.40
30
19.5-29.5
14-29.5
PVC/PVC
MVV-15
12/11/84
742.26 1.43
30
18-28
15-30
PVC/PVC
MW-16
5/16/85
737.20 IL80
30.5
17-27
14-30.5
Teflon/Stainless
MW-17
5/16/85
738.27 1.42
26
13-23
10-26
Teflon Stainless
MW-18
5/17/85
742.33 1.55
24.3
11-21
8.5-24
Teflon/Stainless
MW-20
8/20/87
755.85 2.68
38
22.5-37.5
20-37.5
PVC/PVC
MW-23 s
2/25/88
757.47 3.08
38
20-35
17.7-30
PVC/PVC
MIN-25
3/11/1996
748.02 1.87
40
27-37
24-40
Stainless/Stainless
MW-26
3/8/1996
748.55 2.15
35
22-32
20-35
Stainless/Stainless
MIN-27
3/20/1996
734.05 2.51
33
20-30
16-33
Stainless/Stainless
MW-28
3/15/1996
727.67 2.93
12
6.9-11.9
5.1-12.1
Stainless/Stainless
MW-29
3/20/1996
731.94 2.63
15
35718
8-15
Stainless/Stainless
M V-30
4/21/1997
746.36 flush
35
21-31
18.5-35
Stainless/Stainless
MN-31
4/9/1997
738.00 jf2ush
28
18-28
16-28
Stainless/Stainless
MW-32
4/10/1997
753.43 12.79
40
27-37
25-40
Stainless/Stainless
MW-33
4/10/1997
743.24 2.33
22
11-22
9-22
Stainless/Stainless
MW-34
5/13/1997
739.38 flush
23
13-23
11-23
Stainless/Stainless
MW-35
8/20/1997
720.92 1.95
10.5
5.5-10.5
3.5-10.5
Stainless/Stainless
MiV-36
8/20/1997
728.22 2.15
18
13-18
9.0-18.0
Stainless/Stainless
M[N-37
8/27/1998
713.21
19.5
9.5-19.5
7-19.5
Stainless/Stainless
MW-38
10/9/1998
747.31 Iflush
36
23-33
21-35
Stainless/Stainless
MW-39
9/1/1998
747.58 flush
43.5
33.5-43.5
31-43.5
Stainless/Stainless
MW-40
9/2/1998
746.97 Eush
32.5
22.5-32.5
20-32.5
Stainless/Stainless
MW-41
10/6/1998
748.60
46
3343
3046
Stainless/Stainless
MW-42
9/3/1998
737.37 flush
26
13-23
11-22
Stainless/Stainless
MW43
9/12/1998
730.21 flush
28
15-25
12.5-28
Stainless/Stainless
MW44
10/7/1998
727.29 flush 176
63-73
60-76
Stainless/Stainless
MW-45
10/7/1998
729.39 flush
52
3949
37-50
Stainless/Stainless
1AW-46
9/29/1998 '
731.41 flush
22
12-22
11-22
Stainless/Stainless
MW-47
11/10/1998
688.06 flush
23 10-20
8-23
Stainless/Stainless
MW-48
11/12/1998 697.99
18
8-18 6-18
Stainless/Stainless
MW-49
2/15/1999 684.10
Mush 8
3-8
2-8
Stainless/Stainless
MW-50 2/16/1999
750.45
50
33-48
30-50
Stainless/Stainless
MW-51 12/21/1999
flush 41
27-37
25-41
Stainless/Stainless
MW-52 2/11/1999
705.20
flush 19
9-19
7-19
Stainless/Stainless
NIW-53 3/2/1999
687.48
flush 10
5-10
3-10
Stainless/Stainless
ATW-54 2/11/1999
683.05
25
13-23
9-25
Stainless/Stainless
MW-55 1/6/2000
hush 35
16.5-315
11-33
Stainless/Stainless
MW-56 12/29/1999
Rush 129
16-26
12-29
Stainless/Stainless
vfV -57 1/17/2000
1
flush 38
17-32
15-38
Stainless/Stainless
DW-1 3/11/1996
747.19
1.92 108
95-105
92.8-108
Stainless/Stainless
DS17-2 3/18/1996
1732.83
L60 i50
137-147
133-150
Stainless/Stainless
Dh'-3 3/14/1996
15/14/1997
729.61
2.35 145
132-142
128-145
Starless/Stainless
DAY-4
739.15
Hush 105
92-102
90-105
Stainless/Stainless
DIV-5 9/15/1998
691.61
2.50 177
57-67
55-70
Stainless/
Stainless
R'.4393 prR--%fl= (373.zls-2.'3.'2003

Table 3 Summary of Well Construction Data for Ground Water Monitoring Wells
Duracell LLSA, Lexington, North Carolina
Well
Number
Date
Installed
Top
of Casing Casing
Elevation Stick-up
(ft-MSLl2) (ft-agl)
Total
Depth
(ft-bgll
Screened
Interval
(ft-bgl)
Sand Pack
Internal
(ft-bgl)
Screen/Casing
Material
DW-6
8/31/1998
736.88 2.52
167
155-165
153-167
Stainless/Stainless
DW-7
1/7/1997
743.82 2.51
42
29-39
27-42
Stainless/Stainless
DW-8
11/26/1996
752.67 2.07
144
121-141;91-101
119-145;88-105
Stainless/Stainless
DW-9
1/8/1997
746.92 flush
135.9
122.9-132.9
120-135.9
Stainless/Stainless
DW-10
12/18/1996
733.71 flush
40.2
27.2-37.2
25-40.2
Stainless/Stainless
DW-11
12/6/1996
738.11 Iftush
55.3
42.3-52.3
40-55.3
Stainless/Stainless
DW-12
12/11/1996
741.15 flush
64
Open (50.5-64)
Open
Open (steel outer
casing to 50.5')
DW-13 6
4/18/1997
741.15 flush
193
180-190
175-193
Stainless/Stainless
DW-14
4/3/1997
731.47 3-25
144
131-141
129-144
Stainless/Stainless
DW-15
4/7/1997
732.29 3-12
1108
95-105
93-108
Stainless/Stainless
DW-16
4/4/1997
736.39 2.83
1108
95-105
93-112
Stainless/Stainless
DW-17
4/8/1997
732.31 1.75
200'
Open (57-200)
Oven
Open (steel outer
casing to 57)
DW-18
10/21/1998
742.33 2.54
200
182-197
179-200
Stainless/Stainless
DW-19
10/6/1998
748.75 2.56
112
99-109
96-112
Stainless/Stainless
DW-20
10/22/1998
746.08 flush
200
187-197
185-200
Stainless/Stainless
DW-21
10/8/1998
746.16 flush
102
89-99
87-102
Stainless/Stainless
DW-22
9/24/1998
737.59 flush
173
160170
157-173
Stainless/Stainless
DW-23
9/9/1998
733.21 Lush
201
188-198
186-201
Stainless/Stainless
DW-24
9/17/1998
737.70 'lush
102
89-99
87-102
Stainless/Stainless
DW-25
10/2/1998
722.94 iflush
200
Open (90-200)
Open
Open (steel outer
casing to 90')
DW-26
9/21/1998
734.44 flush
102
84-99
80-102
Stainless/Stainless
DW-27
9/28/1998
709.51 flush
200
Open (41-200)
Open
Open (steel outer
casing to 41')
DW-28
11/10/1998
687.04 flush
95
77-92
74-95
Stainless/Stainless
DW-29
2/26/1999
694.08 flush
105
70-95
68-105
Stainless/Stainless
DW-30
2/12/1999
682.19 flush
90
78-88
75-90
Stainless/Stainless
DW-31
2/17/1999
750.10 184
119
107-117
105-119
Stainless/Stainless
DW-32
12/20/1999
701.16 2.52
83
67-77
64-83
Stainless/Stainless
DW-33
12/16/1999
737.88 flush
178
162-172
159-178
Stainless/Stainless
DW-34
1/7/2000
709.67 flush
69
56-66
54-69
Stainless/Stainless
DW-35
1/5/2000
685.00 flush
205
0pen(50.5-205)
Open
Open (steel outer
casing to 50.5')
DW-36
1/19/2000
660.41 flush
68
55-65
5348
Stainless/Stainless
Notes:
1. ft = feet
2. MSL = Mean Sea Level
3. agl = above ground level
4. bg1= below ground level
5. DW-13 has 66 feet of 10-inch steel casing and 110 feet of 6 5/8-inch steel casing.
P_: _"3s3 PEP_\IITTL,�G,T3.xls -2 3 2003

Table 4 Detected Water Quality Parameters in Shallow (Saprolite) Ground
Water Samples (mg/L) September 1997
Duracell U.S.A., Lexington, North Carolina
Total
Sample Location
Date
Alkalinity
Chloride
Phosphate
Sulfate
TDS
DUR-MW-2
9/ 16/ 97
132
15.8
5.98
15.2
211
DUR-MW-3
9/17/97
42.4
37.2
0.524
149
DUR-MW-10
9/18/97
27.8
239
0.258
620
DUR-MW-29
9/17/97
44.9
12.9
0.23
15.7
147
DUR-SR-6
9/18/97
69
27.7
0.524
13.3
129
DUR-DR-1
9/18/97
109
67.8
0.239
3.25
243
DUR-DW-1
9/17/97
35.1
10.2
1.71
12.7
111
DUR-DW-1 dp
9/17/97
33.7
10.3
1.23
12.9
123
DUR-DW-2
9/9/97
102
8.95
0.54
5.35
875
DUR-PW-4
9/18/97
257
50.2
0.116
11.6
358
DUR-PW-4 dp
9/18/97
247
50
0.138
12.2
352
DUR-PW-5
9/17/97
101
5.22
0.874
35.4
167
MW - shallow monitoring well
SR - shallow recovery well
DW - deep monitoring well
DR - deep recovery well
PTN - private well
Qualifiers
J - estimated value
[ ] - a blank cell indicates parameter analyzed but not detected
P:\4393\P:.&\ff=G\t4.x1s (data (7)-2/5, 2003

Table 5 Detected Volatile Organic Constituents (ug/L) in Ou-Site Shallow (Saprolite) Ground WaterMouitoring Wells
Duracell U.S.A., Lexington, North Carolina
Sample ID
Date
1;1,1-
Trichloro
ethane
1,1,2,2-
Tetrachloro
ethane
1,1-
Dichloro
ethane
1,1-
Dichloro
elhene
1,2-
Dichloro
ethane
1,2-
Dichloro
elhene
(total)
Acetone
Benzene
Bromoforni
Chloro
benzene
DUR-MW-2
4/3/1996
UUR-MW-2
7/11/1996
3 j
DUR-MW-2
5/12/2000
DUR-MW-3
4/4/1996
940
100 j
800
2600
DUR-MW-3
7/10/1996
590
460 j
1900
DUR-MW-3
5/19/2000
150
28 J
170
360
DUR-MW-3 dp
5/19/2000
160 j
36
140 j
390
DUR-MW-4
4/5/1996
6 j
2 j
7 j
3 j
DUR-MW-4
7/10/1996
5 j
1 j
5 j
2 j
41
DUR-MW-5
4/3/1996
8 j
13
DLJR-MW-5
7/9/1996
6 j
8 j
8 j
DUR-MW-5
5/25/2000
3 j
2 j
2 j
DUR-MW-7
4/5/1996
6 j
15
7 j
DUR-MW-7
7/10/1996
5 j
10
6 j
4 j
DUR-MW-7
5/23/2000
4 j
7 j
DUR-MW-8
4/10/1996
DUR-MW-B
7/11/1996
5 j
4 j
4 j
17UR-MW-8 d ,
4/10/1996
DUR-MW-8 dp
7/11/1996
4 j
3 j
4 j
DUR-MW-9
4/5/1996
39
5 j
36
3 j
DUR-MW-9
7/12/1996
42
4 j
27
2 j
DUR-MW-9
5/23/2000
12
3 j
12
DUR-MW-10
4/4/1996
3 j
6 j
4 j
DUR-MW-10
7/10/1996
4 j
5 j
2 j
6 j
DUR-MW-10
5/19/2000
13
6 j
12
UUR-MW-11
4/4/1996
710
100
520
590
8 j
DUR-MW=Il
7/10/1996
750 j
84
370 j
2 j
480 j
22
8 j
DUR-MW-12
4/4/1996
1 j
9 j
4 j
3 j
DUR-MW-12
7/10/1996
DUR-MW-12
5/18/2000
UUR-MW-15
4/8/1996
400
54 j
480
780
P:\4393\PERMITTING\t5.xls voa-wells shall (on) - (2/5/2003)

Table 5 Detected Volatile Organic Constituents (ug/L) in Ou-Site Shallow (Saprolite) Gromid Watel-Monitoriug Wells
Duracell, U.S.A., Lexington, North Carolina
Sample ID
Date
Chloro
ethane
Chloroform
cis-1,3-
Dichloro
propene
Methylene
Chloride
Tetra
chloro
ethene
Toluene
Trichloro
ethene
Vinyl
Chloride
Xylene
(total)
DUR-MW-2
4/3/1996
DUR-MW-2
7/11/1996
DUR-MW-2
5/12/2000
UUR-MW-3
4/4/1996
52.00
DUR-MW-3
7/10/1996
6700
DUR-MW-3
5/19/2000
1800
DUR-1AW-3d1)
5/19/2000
5 )
1500 )
- - -
-- -
DUR-MW-4
4/5/1996
DUR-MWA
7/10/1996
2 )
DUR-MW-5
4/3/1996
51
UUR-MW-5
7/9/1996
4 )
DUR-MW-5
5/25/2000
51
DUR-MW-7
4/5/1996
41
51
DUR-MW-7
7/10/1996
3 1
6 )
DUR-MW-7
5/23/2000
21
51
DUR-MW-8
4/10/1996
DUR-MW-8
7/11/1996
1 )
1 1
DUR-MW-8 Lip
4/10/1996
3 )
25
UUR-MW-8 dp
7/11/1996
1 1
2 1
MR-MW-9
4/5/1996
5 )
3 )
DUR-MW-9
7/12/1996
61
31
UUR-MW-9
5/23/2000
41
1 R
DUR-MW-10
4/4/1996
21
13
DUR-MW-M
7/10/1996
31
71
DUR-MW-10
5/19/2000
1 1
21
301
DUR-MW-"l1
4/4/1996
31 )
910
I)UK-MW-.11
7/10/1996
2 1
6)
12
4 1
980 1
3 J
5 1
DUK-MW-12
4/4/1996
11
4 1
3 )
1)UR-MW-12
7/10/1996
DUK-MW-12
5/1.8/2000
DUR-MW-15
4/8/1996
2600
P:\4393\PERMITnNG\t5.xls voa-wells shall (on) - (2/5/2003)

Table 5 Detected Volatile Organic Constituents (ng/L) in On -Site Shallow (Saprolite) Ground Water Monitoring Wells
Duracell U.S.A., Lexington, North Carolina
Sample 117
Dale
1,7,7-
Trichloro
ethane
1,1,2,2-
Tetrdchloro
ethane
l,l-
Dichloro
ethane
],1-
Dichloro
elhene
1,2-
Dichloro
ethane
1,2-
Dichloro
ethene
(total)
Acetone
Benzene
Bromoform
Chloro
benzene
I U R-M W-15
7/ 10/ 1996
410
390
900
200
DUR-MW-15
5/25/2000
1700
320
1200
1500
UUR-MW-16
4/4/1996
1)UR-MW-16
7/9/1996
DUR-MW-16
6/7/1999
DUR-MW-16
5/18/2000
DUR-MW-"16(1p
4/4/1996
-
—
UUR-MW-16 Lip
7/9/1996
DUR-MW-17
4/3/1996
DUR-MW-1.7
7/9/1996
UUR-MW-17
6/7/1999
DUR-MW-18
4/3/1996
8 J
UUR-MW-18
7/9/1996
DUR-MW-18
6/7/1999
UUR-MW-18
5/23/2000
UUR-MW-20
4/8/1996
3 ]
UUR-MW-20
7/10/1996
UUR-MW-23
4/5/1996
6 J
3 J
U U R-M W-23
7/11/1996
8 J
2 J
DUR-MW-23 dp
4/5/1996
7 J
3 J
DUR-MW-23(1)
7/11/1996
7 J
2 J
DUR-MW-24
4/11/1996
54 J
25 J
280
UUR-MW-25
4/3/1996
11
2 J
160
I)IJR-MW-25
7/11/1996
12 J
2 J
120
UUK-MW-25
10/9/1996
10 J
2 J
110
I )UR-MW-25
5/25/2000
3 J
2 J
62
5 J
UUR-MW-25 Lip
10/9/1996
10
1 J
100
13 J
DUR-MW-26
4/2/1996
DUR-MW-26
7/8/1996
DUR-M W-26
10/9/1996
I )UR-MW-26
5/26/2000
P:\4393\PERMITTING\t5.xls voa-wells shall (on) - (2/5/2003)

Table 5 Detected Volatile Organic Constituents (ug&) in On -Site Shallow (Saprolite) Ground Water Monitoring Wells
Duracell U.S.A., Lexington, North Carolina
Sample ID
Date
Chloro
ethane
Chloroform
cis-1,3-
Dichloro
propene
Methylene
Chloride
Tetra
chloro
ethene
Toluene
Trichloro
ethene
Vinyl
Chloride
Xylene
(total)
UUK-MW-15
7/10/1996
34.00
UUR-MW-15
5/25/2000
23 J
51 J
4200
DUR-MW-16
4/4/1996
UUR-MW-16
7/9/1996
DUR-MW-16
6/7/1999
2 J
UUR-MW-16
5/18/2000
DUR-MW-16 ci
4/4/1996
4 j
DUR-MW-'l6 d
7/9/1996
UUR-MW-17
4/3/1996
QUIZ-MW-17
7/9/1996
MR-MW-17
6/7/1999
1 J
UUK-MW-18
4/3/1996
DIJR-MW-18
7/9/1996
DUR-MW-18
6/7/1999
DUR-MW-18
5/23/2000
DUR-MW-20
4/8/1996
UUR-MW-20
7/10/1996
UUR-MW-23
4/5/1996
2 J
QUIZ-MW-23
7/11/1996
5 J
DUR-MW-23dp
4/5/1996
2 J
DUR-MW-23 d p
7/11/1996
5 J
2 J
UUR-MW-24
4/11/1996
3400 J
38 J
370
DUR-MW-25
4/3/1996
2 J
84
DUR-MW-25
7/11/1996
1 J
2 J
90
DUR-MW-25
10/9/1996
1 J
76
UUK-MW-25
5/25/2000
1 J
2 J
2 J
76
UUK-MW-25 dp
10/9/1996
2 J
81
UUR-MW-26
4/2/1996
UUK-MW-26
7/8/1996
DUR-MW-26
10/9/1996
UUR-MW-26
5/26/2000
1 J
P:\4393\PERMITTING\t5.xls voa-wells shall (on)- (2/5/2003)

Table 5 Defected Volatile Organic Constituents (ug/L) in Ou-Site Shallow (Sallrollle) Ground WaterMonitming Wells
Duracell U.S.A., Lexington, North Carolina
Sample ID
Date
1,1,1-
Trichloro
ethane
1,1,2,2-
Tetrachloro
ethane
1.,1-
Dichloro
ethane
1,1-
Dichloro
ethene
1,2-
Dichloro
ethane
1,2-
Dichloro
ethene
(total)
Acetone
Benzene
Brornoform
Chloro
benzene
DUR-MW-27
4/5/1996
23
9 J
96 1
61
33
DUIZ-MW-27
7/11/1996
30
8 J
72
61
15 J
25
DUR-MW-27
10/10/1996
36
10 J
95
82
30
DUK-MW-27
6/7/1999
11 J
4 J
22 J
51
01-IZ-MW-27
5/16/2000
17
5 J
80
54
DUK-MW-30
9/11/1997
I )UK-M W-30
12/ 18/1997
24
DUIZ-MW-30
5/25/2000
2 J
1 J
DUK-MW-31
9/11/1997
16 J
94
DUK-MW-31
12/17/1997
26
94
12
OUR-MW-31
5/24/2000
5 J
22
3 J
1)UIZ-M W-31 dp
12/17/1997
25
91
12
DUK-MW-33
9/10/1997
DUK-M W-33
12/ 16/ 1997
DUK-MW-33
5/16/2000
DUK-MW-34
9/10/1997
75
33
280
DUK-MW-34
12/16/1997
83
35
260
1)UK-MW-34
5/16/2000
24
17
180
DUK-MW-34 dp
9/10/1997
71
33
280
DUK-MW-38
11/5/1998
86
DUK-MW-38
3/29/1999
1)IJK-MW-39
ll/5/1998
1 J
DUK-MW-39
3/25/1999
1 J
I)UK-MW-411
11/5/1998
1 J
1 J
11
95
DUK-M W-40
3/19/ 1999
5 J
15
140
DUIZ-MW-41
11/5/1998
6 J
11
DIJK-MW-41
3/22/1999
7 J
14
I) IJ K-M W-42
11/5/1998
ULW-MW-42
3/23/1999
1 )UR-SK-6
4/8/ 1996
1000
74 J
1400
1300
DUK-S IZ
7/ 12/ 1996
1200
71 J
1600
2900
P:\4393\PERMITTING\15.x1s voa-wells shall (on) - (2/5/2003)

Table 5 Detected Volatile Organic Constituents (ug/L) in Ou-Site Shallow (Saprolite) Ground Water Monito►-ing Wells
Duracell U.S.A., Lexingtou, North Carolina
Sample Ill
Dale
Chloro
ethane
Chloroform
cis-1,3-
Dichloro
propene
Methylene
Chloride
Tetra
chloro
ethene
Toluene
Trichloro
ethene
Vinyl
Chloride
Xylene
(total)
MR-MW-27
4/5/1996
4 J
5 J
240
34
DUR-MW-27
7/11/1996
3 J
4 J
290
30
])UR-MW-27
10/10/1996
8 J
5 J
3.20
34
I )lJR-MW-27
6/7/1999
210
MR-MW-27
5/16/2000
3 J
2 1
2.70
OUR-MW-30
9/11/1997
DUR-1AW-2A)
12/19/1997
31
DUR-M W-3Tl
5/ 25/ 2000
J
MR-MW-31
9/11/1997
880
DUR-MW-31
12/17/1997
2 J
910
UUR-MW-31
5/24/2000
1 J
290
DUR-MW-31 d,
12/17/1997
2 1
850
DUR-MW-33
9/10/1997
DUR-M W-33
12/ 16/ 1997
1)UR-MW-33
5/16/2000
DUR-MW-34
9/10/1997
5 J
UUR-MW-34
12/16/1997
7 J
DUR-MW-34
5/16/2000
4 1
1 J
DUR-MW-34 dp
9/10/1997
5 J
DUR-MW-38
11/5/1998
4 J
DUR-MW-38
3/29/1999
3 J
DUR-MW-39
11/5/1998
1 J
2 J
3 J
DUR-MW-39
3/25/1999
6 J
DUR-MW-40
11/5/1998
3 J
8 J
90
DUR-MW-40
3/19/1999
170
DUR-MW-41
11/5/1998
4 J
5 J
5 J
UUR-MW-41
3/22/1999
2 J
MR-MW-42
11/5/1998
5 J
Ul)R-MW-42
3/23/1999
UR-SR-6
4/8/1996
62 J
1700
I)UR-SR-6
7/12/1996
47 J
3200
P:\4393\PERMITTING\t5.xls voa-wells shall (on) - (2/5/2003)

'1 able 5 Detected Volatile Organic Constituents (ug/L) in On -Site Shallow (Saprolite) Ground Water Monitoring Wells
Duracell U.S.A., Lexington, North Carolina
Sample ID
Date
1,1,1-
Trichloro
ethane
1,1,2,2-
Tetrachloro
ethane
111-
Dichloro
ethane
1,1-
Dichloro
ethene
1,2-
Dichloro
ethane
1,2-
Dichloro
ethene
(total)
Acetone
Benzene
Bromoform
Chloro
benzene
I)UR-PLTI-GW2
7/5/2000
1 120
5 J
150 1
2 J
2 J
DUR-1'1,7'1-GW3
7/7/2000
61
DUR-P'LTJ-GW4
7/6/2000
160)
2100
6100
DUR-PI.TI-GW5
7/7/2000
130 J
9 1
J
I.)UR-]'LTJ-GW6
7/7/2000
41
81
22
0.41
DUR-PI.:l'J-GW6 d p
7/7/2000
I BUR-PLTJ-GW7
7/6/2000
2 ]
DUR-PI.Tl-GW8
7/7/2000
DUR-1wri-GW9
7/7/2000
21
31
-
DUR-1I:11-CM10
7/7/2000
21
P:\4393\PERMITTING\t5.xls voa-wells shall (on) - (2/5/2003)

•ound Water Monitoring Wells
bluene
Trichloro
ethene
Vinyl
Chloride
Xylene
(total)
3500
31
7000
170000
ss
71
21
91
31
P:\4393\PERMITTING\t5.xls voa-wells shall (on) - (2/5/2003)

Table 5 Detected Volatile Organic Constituents (ug/L) in Off -Site Shallow (Saprolite) Ground Water Monitoring Wells
Duracell U.S.A., Lexington, North Carolina
Sample 1D
Date
1,l,l-
Trichloro
ethane
1,1,2,2-
Tetrachloro
ethane
1,1,2-
Trichloro
ethane
111-
Dichloro
ethane
111-
Dichloro
ethene
1,2-
Dichloro
ethene
(total)
Acetone
Bromoform
Chloroform
MelhyIene
Chloride
Tetra
chloro
ethene
Trichloro
ethene
DIJR-MW-28
4/8/1996
98
1
48
300
380
1
4 j
490 J
OUR-MW-28
7/11/1996
88
40
220
330
480
DUR-MW-28
10/1.0/1996
65
33
190
260
370
DUR-MW-28
6/7/1999
4 j
2 J
I)UR-MW-28
5/16/2000
8 j
DUR-MW-28dp
6/7/1999
5 j
1 J
DUR-MW-29
4/8/1996
6200 j
I)LJR-MW-29
7/11/1996
2 j
DUR-M W-29
10/ 10/ 1996
DUR-MW-29
5/16/2000
1-)t1R-MW-32
9/11/1997
2 j
I) U R-M W-32
12/ 17/ 1997
DUR-MW-32
6/7/1999
2 j
DUR-MW-32
5/18/2000
5 J
DUR-MW-35
9/9/1997
3 j
3 j
9 J
11
30
58
DUR-MW-35
12/16/1997
42
18
110
180
2 J
230
DUR-MW-35
6/7/1999
1G j
6 j
27
89
190
DUR-MW-35
5/16/2000
10
4 j
22
43
97
DUR-MW-36
9/9/1997
13
13
56
120
150
DUR-MW-36
12/16/1997
12
4 j
16
26
2 J
92
DUR-MW-36
5/16/2000
6 J
2 j
12
22
1 J
70
DUR-MW 36 dp
5/16/2000
4 J
2 j
10
16
1 J
.66
DUR-MW 17
11/5/1998
240
65
29 j
7 j
470
DUR-MW-37
3/18/1999
260
56
25 J
550
DUR-MW-43
11/11/1998
2 j
17
6 j
3 j
200
DUR-MW-43
3/17/1999
4 j
2 J
110
DUR-MW-44
17/ll/1998
120
340
1100
DUR-MW-44
3/1.9/1999
53 J
97 j
280
1100
DUR-MW-45
11/10/1998
48 j
140
880
1800
DUR-MW-45
3/18/1999
40 J
110 j
920
1600
DUR-M W-46
11/ 19/ 1998
DUR-MW-46
3/25/1999
DUR-MW-46 d p
11/19/1998
17 U R-M W-47
11 /30/ 1998
P:\4393\PERMITTING\t5.xls VUA-wells shall (off) - (2/5/2003)

Table 5 Detected Volatile Organic Constituents (ug/L) in Off -Site Shallow (Saprolite) Ground Water Monitoring Wells
Duracell U.S.A., Lexington, North Carolina
Sample ID
Date
1,1,1-
Trichloro
ethane
1,1,2,2-
Tetrachloro
ethane
1,1,2-
Trichloro
ethane
1,1-
Dichloro
ethane
1,1-
Dichloro
ethene
1,2-
Dichloro
ethene
(total)
Acetone
Bromoforni
Chloroform
Methylene
Chloride
Tetra
chloro
ethene
Trichloro
ethene
DUR-MW-47
12/3/1998
3 J
1 J
1 J
DUR-MW-47
3/24/1999
DUR-MW-47 d)
3/24/1999
DUR-MW-48
11/30/1998
2 J
2 J
3 J
9 J
DUIt-MW-48
12/4/1998
2 J
2 J
3 J
9 J
DUR-MW-48
3/30/1999
2 J
2 J
2 J
9 J
DUR-MW-49
4/16/1999
DULL-MW-49
10/6/1999—
DUR-MW-53
3/22/1999
DULL-MW-53
10/6/1999
4 J
DUILMW-54
3/10/1999
8 J
5 J
54
450
390
DUR-MW-54
10/6/1999
5 J
4 J
25 J
350 J
200 J
DUR-M W-55
1/20/2000
DUR-MW-55
2/24/2000
I )U R-M W-55
5/ 11 /2000
DUR-MW-56
I/18/2000
43 J
8 J
DUR-MW-57
1/20/2000
2 J
2 J
DU12-MW-57
3/l/2000
DUR-MW-57
5/10/2000
I )IJR-MW-57 dp
1/20/2000
2 J
2 J
SR - shallow recovery well
N1W - shallow uconilurimg well
1TTI-CM- plant #1 ground water sample
dp - duplicate field sample
Qualifiers
J - estimated value
[ J - a blank cell indicates parameter analyzed but not detected
P:\4393\PHRM17TING\t5.x1s VOA -wells shelf (off) - (2/5/2003)

Response: The basic operations to be performed will consist of preparing the
permanganate solution and injecting it into the subsurface through temporary
Geoprobe points. The following operating data will be collected as part of the
injection process.
Solution Make -up --For each batch of solution prepared the following data will
be recorded:
• Date and time batch was prepared.
• Volume of water used
• Weight of permanganate added
• Verification of concentration by photometric analysis.
Injection Points ---At each injection point and interval the following data will be
recorded:
• Location of injection point
• Date and time of injection
• Depth of injection
• Volume of solution injected
• Injection rate
• Time to complete injection
• Estimate of spillage on the ground surface, if any
M. INJECTION -RELATED EQUIPMENT
Attach a diagram showing the detailed plans and specifications of the surface
and subsurface construction details of the system.
Response: A schematic diagram of the Geoprobe and injection tip is provided in
Figure 16. Since the injection of the chemical oxidant will be through temporary
Geoprobe points, there will be no subsurface construction activities.
N. LOCATION OF WELL(S)
Attach a scaled, site -specific map showing the location(s) of the following:
(1) the proposed injection well(s);
(2) all property boundaries;
(3) the direction and distance from the injection well or well system to two
nearby, permanent reference points (such as roads, streams, and highway
intersections);
(4) all buildings within the property boundary;
(5) any other existing or abandoned wells, including water supply and
monitoring wells, within the area of review of the injection well or wells
system,
(6) potentiometric surface showing direction of groundwater movement,
(7) any existing sources of potential or known groundwater contamination,
including waste storage, treatment or disposal systems within the area of
review of the injection well or well system; and
GW-57 REM (Jan, 2000) Page 15 of 18

(8) all surface water bodies within the area of review of the injection well or
well system.
Response: The following maps are provided in Attachment B for review:
Figure B-1: Site Location Map -- Portion of West Lexington and East Lexington
Quadrangle USGS Topographic Maps
Figure B-2: Site Map (show all property boundaries & all buildings within the
property boundaries)
Figure B-3: Site Topographic Map
Figure B-4: Partial Site Layout Map with Locations of Hydrogeologic Profile
Lines A -A' and B-B'
Figure B-5: Hydrogeologic Profile A -A'
Figure B-6: Hydrogeologic Profile B-B'
Figure B-7: Cross Section N through S
Figure B-8: Cross Section NNE through SSW
Figure B-9: Cross Section NNW through SSE
Figure B-10: Cross Section WNW through ESE
Figure B-11: Locations of Hydrogeologic Cross -Sectional Profiles
Figure B-12: Ground Water Elevation Contour Map for Shallow System — May
2000
Figure B-13: Ground Water Elevation Contour Map for Deep System -- May
2000
Figure B-14: Surface Water Location Map - Portion of West Lexington and East
Lexington Quadrangle USGS Topographic Maps (show all surface
water bodies within 1,000 ft of injection point)
Figure B-15: Map showing location of all wells (incl. abandoned, supply and
monitoring, and proposed injection wells) in area of review
Figure B-16: Private Well Locations Within 1/2 Mile Radius
Figure B-17 VOC Distribution Map for Soil to be Remediated and Temporary
Injection Point Layout
Figure B-18: Subsurface Application Schematic
O. INJECTION FLUID DATA
(1) Fluid source, if underground, from what depth, formation and type of
rock/sediment unit will the fluid be drawn (e.g., granite, limestone,
sand, etc.).
Depth:
GW-57 REM (Jan, 2000) Page 16 of 18

Formation:
Rock/sediment unit:
(2) Provide the chemical, physical, biological and radiological characteristics
of the fluid to be injected.
Response: Part 1: This does not apply; the fluid source is not underground.
Part 2: The MSDS and Carus fact sheet for Sodium Permanganate
are included in Attachment C. The MSDS contains chemical,
physical, biological and radiological characteristics of the fluid to be
applied. Sodium permanganate is proposed to be applied as a 4 to
4.5 % solution.
P. PERMIT LIST
Attach a list of all permits or construction approvals that are related to the site,
including but not limited to:
(1) Hazardous Waste Management program permits under RCRA
(2) NC Division of Water Quality Non -Discharge permits
(3) Sewage Treatment and Disposal Permits
(4) Other environmental permits required by state or federal law.
Response: No additional permits are expected to be required for the chemical
oxidation process.
Q. CERTIFICATION
"I hereby certify, under penalty of law, that I have personally examined and am
familiar with the information submitted in this document and all attachments
thereto and that, based on my inquiry of those individuals immediately
responsible for obtaining said information, I believe that the information is true,
accurate and complete. I am aware that there are significant penalties, including
the possibility of fines and imprisonment, for submitting false information. I
agree to construct, operate, maintain, repair, and if applicable, abandon the
injection well and all related appurtenances in accordance with the approved
specifications and conditions of the Permit."
(Signature of Owner or Authorized Agent)
Please supply a letter signed by the owner authorizing
the above agent, if authorized agent is signer.
Identify acting responsible party for the remediation/cleanup of the site.
GW-57 REM (Jan, 2000) Page 17 of 18

R. CONSENT OF PROPERTY OWNER (Owner means any person who holds the
fee or other property rights in the well being constructed. A well is real property
and its construction on land rests ownership in the landowner in the absence of
contrary agreement in writing.)
If the property is owned by someone other than the applicant, the property
owner hereby consents to allow the applicant to construct each injection well as
outlined in this application and that it shall be the responsibility of the applicant
to ensure that the injection well(s) conforms to the Well Construction Standards
(Title 15A NCAC 2C .0200)
Identify current owners of properties associated with the site. Representatives
from all ownership groups must sign the permit application.
(Signature Of Property Owner If Different From
Applicant)
Please return two copies of the completed Application package to:
UIC Program
Groundwater Section
North Carolina DENR-DWQ
1636 Mail Service Center
Raleigh, NC 27699-1636
Telephone [phone]
GW-57 REM (Jan, 2000) Page 18 of 18

Attachment A
Laboratory Treatability Study Report

KEMRON ENVIRONMENTAL SERVICES, INC.
DURACELL FACILITY
Lexington, North Carolina
1.0 INTRODUCTION
1.1 TERMS OF REFERENCE
This report was developed as a presentation of the results of the stabilization/solidification and
oxidation treatability testing conducted for the Duracell site located in Lexington, North Carolina
(Duracell -Lexington Site). Stab ilization/sohdification testing has been conducted to date on soil
samples collected from areas to be remediated due to the presence of mercury. Oxidation
treatability testing has been conducted employing soil and ground water from areas to be
remediated for volatile organic compounds (VOCs) and using the VOCs that are of concern at
the site. The treatability testing was performed for Environmental Resources Management
(ERM) and Duracell (the Client) to identify remedial alternatives for the site. All testing
summarized herein was performed in general accordance with the scope of work presented in the
approved Treatability Study Work Plan for the site. Modifications to the scope of work were
made throughout the study based on discussions with ERM and Duracell. This report presents
the results of all testing and analyses performed as a part of this bench -scale remedy screening I
verification treatability study to date.
1.2 SCOPE OF WORK
Kemron undertook two separate and independent scopes of work for the Duracell -Lexington site.
The first scope of work pertained to stabilization/solidification treatability testing and the second
scope of work involved oxidation treatability testing. The following discussions summarize
these testing programs and the results.
The primary objective of the stabilization/ solidification treatability study was to conduct a
bench -scale evaluation of solidification mixtures capable of successfully meeting the treatment
performance criteria established for the site. Specifically, the stabilization/ solidification
treatability study was performed to 1) determine the untreated characteristics of soils sampled
from locations with mercury concentrations that exceed the remedial goal established for the site,
�) evaluate a range of potential reagents and reagent addition rates for solidification of the these
`ZSi���S_102 Page 1 of 28 IILRON ENVIItONMENT.4L JERVICES, INC.
?APPLIED TECHNOLOGIES GROUP

soils, 3) perform additional evaluations to optimize treatment of the soils, and 4) improve the
physical properties of the soil for long-term stability.
The stabilization/ solidification treatability study was performed in a phased approach. The first
phase included characterization of untreated soil. Following baseline characterization of the
untreated soil, Kemron performed preliminary and intermediate solidification evaluations to
assess the performance of various reagents and reagent addition rates. Verification solidification
evaluations were performed to optimize candidate treatment and evaluate the potential need for
further treatment alternatives. Kemron performed the stabilization/solidification testing on two
categories of untreated soil composites. While both composites were of soils that contained
mercury at a concentration that exceeds the remedial goal established for the site, one composite
soil sample contained metallic mercury visible to the unaided eye (visible mercury sample) and
the second composite soil sample did not contain metallic mercury visible to the unaided eye, but
did contain mercury at a concentration of greater than 100 mg/kg (>100 ppm sample). The
stabilization/solidification treatment testing was designed to reduce the leachable concentrations
of the contaminants of concern, manganese and mercury, and improve the physical properties of
the treated soil.
The primary objective of the oxidation treatability study was to demonstrate that the chemical
oxidation techniques can meet or exceed the remedial goals for protection of ground water.
Specifically, the oxidation treatability study was performed to 1) determine the untreated
characteristics of groundwater sampled from the site, 2) evaluate a range of potential reagents
and reagent addition rates for oxidation of constituents of concern in site groundwater, and 3)
perform additional evaluations to determine the total oxidation reagent soil demand.
1.3 REPORT ORG-ANIZATION
This report presents the sample tracking information, the test methods and protocols, and the
results of analyses and testing conducted throughout the treatability study. The report has been
divided into sections presenting the various phases of the treatability study. The following
sections of the report summarize the various phases of the treatability study:
• Section 2.0 — Phase I: Untreated Soil Characterization
• Section 3.0 — Phase H: Stab ilization/solidification Screening/Verification
• Section 4.0 —Phase HL Chemical Oxidation Screening
• Section 5.0 — Conclusions/Recommendations
• Section 6.0 — Quality Assurance (QA) and Quality Control (QC)
3 � /3555_102 Page 2 of 28 KE vfRO� ENvaOv Er i 4l SERVICES, LNC.
-A-PPLTED TECiLNOLOGIES GROUP

Following the main text are tables and figures summarizing all data developed as part of the
treatability study. Appendices are presented at the end of the document and include complete
analytical data packages and geotechnical data reports. Note that most of the analytical testing
was performed by a subcontract laboratory (CompuChem) under the direction of the Client_ As
such, analytical data reports were provided directly to the Client and are not included herein.
355513555 102 Page 3 of 28 PE-mRo-N EN. ,?RomviENT_AL S-RviCEs, Laic.
�PPT T- GROT_P

2.0 PHASE I: UNTREATED SOIL CHARACTERIZATION
2.1 OVERVIEW
The establishment of the baseline level of constituents of concem is important for comparing and
determining the effectiveness of the various treatment processes evaluated. The analyses also
allow verification that the samples are representative and consistent with expectations and
previous samples. This section presents information on the sampling, handling, preparation and
characterization of the untreated soils utilized in the treatability study.
2.2 SOIL SAMPLING AND RECEIPT
On 30 August 2001 Kemron received twenty three untreated soil samples labeled Visible
Mercury (visible composite) and twenty eight untreated samples labeled as >100 ppm Mercury
(>100 composite) for the stabilization/ solidification study. For the oxidation treatability study,
three additional untreated soil samples were received. Ten liters of groundwater to be used in the
oxidation treatability study were received on 28 September 2001 from the Duracell site. Each
container was labeled and represented a distinct sample of untreated soil (or ground water). All
samples were received in good condition.
Upon receipt, all materials were logged in and placed in secure refrigerated storage at a
temperature of 4 °C until commencement of treatability testing. Upon authorization to proceed
with the study, Kemron developed two composite soil samples (visible mercury and >100 ppm
mercury) for use in the stabilization/ solidification treatability study. The composite samples
were developed using the procedures and individual samples outlined by the Client and in
accordance with the intent of the Treatability Work Plan. Kemron generated the untreated
composite samples by placing aliquots of each of the individual soil samples into large blending
containers. Once the materials had been added to the blending container, Kemron homogenized
each composite sample. Homogenization was conducted by placing each untreated composite
soil sample into a mixing pan and gently mixing with stainless steel utensils. For treatability
testing, Kemron typically removed all particles or debris (rocks, wood, etc.) larger than 0.5
inches (1 cm.) in diameter. Note that less than 1 % by weight of oversized material was present
in the samples received by Kemron. Kemron continued homogenizing the composite, by hand,
until visually homogenous, over a period of approximately 10 to 15 minutes. Upon completion,
the homogenized materials were placed into clean 5-0rallon plastic buckets, covered with a lid,
and p1_aced in refrigerated storage.
5i-3 -55_102 Page 4 of 28 KEv1RON EN��O\ It\T_�I SER`'ICES, LNC.
APPLIED 'I`LC1-1N0L0GI7--S GROLP

The groundwater samples were homogenized by mixing all ten liters of water in a clean plastic
container, returning the water into the original shipping bottles and placing them in refrigerated
storage. The three soil samples used for the oxidation treatability study were also homogenized
in accordance with the above procedure.
2.3 UNTREATED SOIL CHARACTERIZATION
Untreated soil characterization was performed both on "as -received" samples and on the two
composite samples developed for treatability testing. The following discussion summarizes the
results of these analyses.
"As -Received" Sample Analyses
Kemron performed geotechnical evaluations of the "as -received" samples in accordance with
specifications on the chain of custody provided by ERM: soil samples using our in-house
laboratory for physical testing. The following analyses were performed on 18 of the "as -
received" soil samples in accordance with the specified method:
Parameter
Moisture Content
Bulk Density
Method
ASTM D 2216
ASTM D 5057
Atterberg Limits ASTM D4318
Particle Size Distribution with Hydrometer ASTM D422
Mica Content
Falling Head Permeability
NA
ASTM D5084 / EPA 9100
Four of the "as received" soil samples were analyzed for the following parameters in accordance
with the specified method.
Parameter
Material pH
Falling Head Permeability
Method
EPA Method 9045C
ASTM D5084/ EPA 9100
The results of these analyses are summarized in Tables 1 through 3.
555i3555 102 Patre 5 of 28 PLvtRoN E\r,ZRo-,N i AL SERI7CES, LTC.
APPLIED T-cz�, , =-s GROUP

Table 1
As -Received Materials
Summary of Geoleclinical Analyses
Kemron Environmental Services, Inc.
Duracell - Lexington Site Trealability Study
SAMPLE
1 D
Moisture Content
(%)
Bulk Density
(11)s/1t3)
OEOTECHNICAL
Atterberg
Lunits
PARAMETER
Particle
Size Distribution
("/")
Estimated
Mica ("/o)
Dry Basis
Wet Basis
Liquid limit
Plastic Limit
Plasicity Inde
Gravel
Sand
Silt
Clay
PS-1 (0'-4')
PS-2 (0'-4')
PS-3 (0'-4')
PS-4 (0'-4')
PS-5 (0'-4')
513-208 (22'-26')
S13-208 (26'-30')
SB-355 (7-8)
5.13-355 (8'-9')
513-355 (14'-16')
SB-355 (21'-23')
513-355 (28'-30)
S13-359 (15'-19')
SB-359 (23'-27')
513-362 (14'-18')
513-362 (26'-30')
513-369 (14'-18')
SB-369 (22'-26')
27.8
25.6
18.2
24.7
15.8
22.1
31.2
16.0
26.8
25.8
19.5
45.8
32.1
31.5
21.1
32.9
23.4
24.3
21.8
20.4
15.4
19.8
13.6
18.1
23.8
13.8
21.1
20.5
16.3
31.4
24.3
23.9
17.4
24.8
19.9
19.5
119
106
117
123
114
108
122
117
124
121
82
120
114
117
135
125
93
120
60
49
40
43
NL
35
37
35
43
40
NL
NL
48
60
37
36
40
43
28
35
21
22
NP
30
24
20
23
21
NP
NP
31
32
20
30
37
31
32
14
19
21
NA
5
13
15
20
19
NA
NA
17
28
17
6
3
12
0.5
0
11.8
16.6
0.9
0
0
7.7
2.3
0.2
0
0
0
0
0
0
0
0
26.3
32.3
27.0
21.7
70.6
51.0
47.6
57.1
31.4
30.7
71.8
36.5
30.0
49.0
27.5
52.7
47.5
44.6
30.6
34.7
40.4
35.4
19.4
44.1
45.9
23.4
38.8
39.3
26
56.6
40.3
29.5
47.2
42.2
44.8
48.4
42.6
33
20.8
26.3
9.1
4.9
6.5
11.8
27.5
29.8
2.2
6.9
29.7
21.5
25.3
5.1
7.7
7.0
10
35
15
35
40
35
40
15
15
15
30
30
30
15
35
30
30
30
NL No Liquid Limit
NJ' No Plastic Limit
NA Not Applicable
3555 "l()S.xls
Kemron Environmental Services, Inc.
Applied Technologies Group

Table 2
As -Received Materials
Summary of Falling Head Permeability Testing
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
SAMPLE
HYDRAULIC CONDUCTIVITY
Moisture
Bulk
Dry
Permeability
ID
Content (%) c1)
Density (lbs/ft')
Density (lbs/ft')
(cm/sec)
SB-208B @ 26-30 Ft.
26.3
124.2
98.4
1.3 x 10-6
SB-355 @ 28-30 Ft.
4L6
108.3
76.5
7.6 x 10-6
SB-359 @ 23-27 Ft.
26.0
113.5
90.1
9.8 x 10-6
SB-362 @ 26-30 Ft.
25.8
122.9
97.7
1.5 x 10-5
(1) Moisture Content determined in accordance with ASTM D2216 (dry weight basis)
Ke=on Environmental Sen.-ices, Inc.
3555_206_x1s Applied Technologies Group

Table 3
As -Received Materials
Summary of Geotechnical Analyses
Kemrou Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
SAMPLE
CONFIRMATION
TESTING
Moisture
Bulk
Dry
Specific
Saturation
1)II(2)
ID
Content N
Density (lbs/ft')
Density (lbs/ft')
Gravity
N
(s.u.)
SB-355 @ 21-23 Ft.
18.2
89.0
75.3
2.70
39.6
7.4
SB-355 @ 28-30 Ft.
37.6
111.3
80.9
2.70
93.8
6.4
SB-362 @ 14-18 Ft.
19.1
130.5
109.6
2.72
94.6
7.0
SB-362 @ 26-30 Ft.
23.8
121.0
97.7
2.79
84.3
6.1(3)
(1) Moisture Content determined in accordance with ASTM D2216 (dry weight basis)
(2) Results is an average of three different determinations
(3) "fesling performed on oven dried material, as received material was not available.
Material for tube SB-355 @ 21-28 Fl, was very dry and loosely compacted.
Kentron Environmental Services, Inc.
Applied Technologies Group
3555 210.x1s

Composite Analvses
Once homogenization was complete, Kemron sampled aliquots of each untreated soil composite
for characterization testing. Untreated characterization is an essential component of the
treatability study. The establishment of the baseline level of contamination is important for
comparing and determining the effectiveness of the treatment processes. The characterization
analyses also allow for confirmation that the chemical and physical properties of the soil samples
were similar to those expected at the site. Table 4 present the results of all untreated
characterization analyses for the stabilization/solidification treatability study.
SPLP analyses on the untreated composite soil samples were performed by CompuChem of Cary,
North Carolina. All analyses were performed under the direction of the Client and were reported
directly to the Client. The data reported herein for these analyses have been provided to Kemron
by the Client. Note that all geotechnical analyses performed on the untreated composite samples
were performed by Kemron. The following analyses were performed on aliquots of the untreated
composite samples:
Parameter
SPLP Mercury
SPLP Manganese
Moisture Content
Bulk Density
Material pH
Method
EPA Methods 1312/7470A
EPA Methods 1312/6010B
ASTM D 2216
ASTM D 5057
EPA Method 9045C
The results of the above analyses are summarized in Table 4. Review of the data summarized in
this table reveals that SPLP leachable mercury was reported at concentrations of 111 ug/L for the
>100 Composite and 723 ug/L for the Visible Composite. Manganese was detectable at
concentrations of 20 ug/L for the >100 Composite and 82.2 ug/L for the Visible Composite.
Physical properties of the two composite soil samples were nearly identical.
5i3555_102 Page 6 of 28 KEMRO\ E\"vIRO\NENT4L SER`iCES, I\C.
APPLIED TECHNOLOGIES GROUP

Table 4
Untreated Material Composites
Summary of Baseline Characterization
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
ANALYTICAL
PARAMETER
UNIT
> 100
COMPOSITE
VISIBLE
COMPOSITE
GEOTECHNICAL ANALYSES
Moisture Content @ 110'CO)
- Dry Basis
%
27.67
30.00
- Wet Basis
%
21.34
23.03
Bulk Density (1)
lb/ft3
117.5
117.7
Bulk Specific Gravity (1)
-
1.9
1.9
Material pH (1)
s.u.
7.82
7.89
CHEMICAL ANALYSES
SPLP Mercury
ug/L
111
723
SPLP Manganese
ug/L
20
82.2
(1) Results are an average of three determinations.
3555 207_Xls
Kern on Environmenial Senices, Inc.
Applied Technolo-oies Group

3.0 PEASE IL STABILIZATION/SOLIDIFICATION SCREENING
3.1 OVERVIEW
Stabilization/solidification treatment was selected as a candidate remedial technology for soils
containing mercury due to its 1) relative ease of implementation, 2) ability to reduce the
leachability, and therefore mobility, of both organic and inorganic contaminants, including
mercury, 3) proven success in remediating sites containing soils with inorganic contaminants,
and 4) relatively low cost of implementation. Stabilization/solidification technologies have
proven capable of remediating sites with a broad range of both organic and inorganic
contaminants. Further, the technology is capable of being implemented usimgboth locally
available equipment and locally available reagents. Finally, the time to treat the site using
stabilization/solidification technologies is anticipated to be equal to or less than the time required
for treatment with any of the other remedial technologies being evaluated.
The initial task of Phase H of the Duracell site treatability study was designed to identify
potential reagents and reagent concentrations capable of successfully stabilizing / solidifying the
untreated material, as based on immobilizing mercury as measured by a reduction in the
leachability of mercury. The primary applications of solidification include 1) treatment of liquids
and sludges for land disposal, 2) remediation of sites containing organic and inorganic
contaminants, and 3) solidification of materials which are physically unstable. Stabilization
treatment is identified in the National Contingency Plan (NCP) as a permanent remedial
alternative for treatment of organic and inorganic waste materials. To perform stabilization
treatment, common binding reagents or proprietary reagents are added to the untreated waste
materials. Common binding agents include cement, fly ash, hydrated lime, cement kiln dust and
lime kiln dust. In the remainder of this discussion, the terms solidification, stabilization and
immobilization will be used interchangeably.
Effective treatment is evaluated through a review of the properties and characteristics produced
by mechanisms of stabilization. Successful treatment of the contaminated media is dependent on
the following stabilization mechanisms:
• Macro encapsulation
• Micro encapsulation
• Adsorption
Detox; fi cation
3555/3555_102 Page 7 of 28 KEMRO\ EN-\ IRO\ E\T_;L SER,\TCES, LNc.
ADPLIED TECHNOLOGES GROUP

Macro encapsulation is the mechanism by which contaminants are physically entrapped as
agglomerated particles within the bulk physical structure, or monolith, formed by stabilization
reagents. Micro encapsulation, by contrast, occurs when contaminants are entrapped within the
crystalline structure of the stabilization reagents. Stabilization reagents are frequently selected
based on the ability of the reagents to generate the cementitious reaction necessary to bind and
encapsulate the contaminants into a low permeable crystalline structure.
Physical encapsulation of the contaminants within the stabilization monolith and crystalline
structure is often not sufficient to meet long term treatment goals, since physical degradation
may over time enhance contaminant migration. In order to achieve effective long-term
stabilization, contaminants must often be chemically bonded or adsorbed within the stabilized
matrix. Common stabilization reagents, such as cement, will often provide the necessary binding
mechanisms.
Adsorption and detoxification are not considered to be significant treatment mechanisms for the
reagent classes and contaminants being assessed. Adsorption can occur when a contaminant is
bound, typically electrostatically, to active sites on a stabilization media. An example would be
high molecular weight organics being bound to activated carbon.
3.2 REAGENT SELECTION
Kemron selected reagents to be evaluated based on experience stabilizing / solidifying similar
materials. For the purposes of this study, Kemron focused on non-proprietary and non -patented
treatment alternatives. While many patented or proprietary reagents are available for
stabilization, Kemron feels that there are a number of equally effective non-proprietary, non -
patented reagents available. As such, Kemron focused on these readily available and proven
non-proprietary, non -patented reagents.
Preliminary stabilization/solidification focused on the use of Type I Portland cement. Cement is
the most common reagent utilized in the stabilization/solidification of materials (soils and
wastes) containing hazardous substances. In addition to evaluating cement alone, treatment was
also performed to evaluate cement in combination with other common binding reagents,
including hydrated lime and slag cement. These binding reagents, while not providing all of the
benefits of cement, are often used in conjunction with cement. Combining these reagent types
can often allow for lower cement addition rates, thereby reducing potential full-scale reagent
volumes and mi imizing the volume of the stabilized material. Kemron evaluated these binding
35>j/21»>_102 Page 8of28 PEmRONENvaONTNIBNNLAL.SDRVICES,LNC.
�PPL FD TEC_-LNOLOGIEs GRou

reagents in conjunction with cement in an effort to identify potentially technology -effective
reagent combinations. In addition to these two common binder reagents, Kemron also evaluated
several chemical additives including sodium sulfide and ferrous sulfate. These additives were
selected due to their proven ability to minimize mercury mobility.
3.3 BLENDING TECHNIQUES AND SAMPLE FORMATION
During this phase of the study, the Client and Kemron outlined a variety of reagent types and
addition rates that have been proven capable of effectively improving the physical and chemical
properties of similar untreated material types. Specific reagents and reagent combinations
evaluated included:
• Type I Portland Cement
• Portland Cement/ Sodium Sulfide
• Portland Cement/ Lime
• Portland Cement / Lime/ Sodium Sulfide
• Slag Cement/ Sodium Sulfide
• Slag Cement/ Lime/ Sodium Sulfide
All reagents were added as a slurry. Water was added as necessary to achieve a final treated
material consistency similar to a very low slump concrete. Review of the particle size data
reveals that the site soils are silty sands with some various fractions of clay. Experience indicates
that materials with these size characteristics are amenable to a wide range of treatment options
and have been successfully treated on other sites.
Table 5 summarizes the initial mixtures developed by the Client and Kemron. This table
includes Kemron's mixture numbers, the types of reagents used for each mixture, and the reagent
addition rates for each mixture. The mixtures were developed by placing an aliquot of untreated
composite soil sample into a blending chamber. The specified reagent was slurried with the
specified amount of water and added to the untreated soil and blended at a rate of 30 to 50
rotations per minute (rpm) for a period of 30 to 60 seconds, until visually homogenous. Once
homogenous, each of the treated mixtures was transferred to cylindrical molds for curing. Each
treated mixture was allowed to cure in a humid environment maintained at a temperature of 16 to
20 degrees Celsius (°C).
3555 35>j 102 Page 9 of 28 KEViRONEl vtON7i%r.~1T�? S--«C-s, D C.
APPL ED T C:7iTOLOGIFS GROL-P

3.4 TREATED EVALUATIONS
Upon reaching specified cure intervals, the treated materials were subjected to physical
characterization testing. During the curing process, treated materials were evaluated for setting
and strength properties through penetrometer strength testing. While it is difficult to correlate
penetrometer data to potential UCS (unconfined compressive strength) values, penetrometer
values in excess of 4.5 tons per square foot (tons/ftz) generally indicate good strength
characteristics. A review of data in Table 5 reveals that all mixtures, except two, achieved
penetrometer strength values in excess of 4.5 tons/ftz after 1 to 4 days of curing. The two
remaining mixtures achieved penetrometer strength values of 3.75 tons/ftz and >4.5 tons/ftz after
7 days of curing. The two mixtures that did not achieve the desired 4.5 tons/ftz after four days
were both visible composite soil with slag cement/sodium sulfide. It was observed that the slag
cement/sodium sulfide mixtures in the >100 composite soil samples had the lowest penetrometer
readings after curing for one day. This indicates that this reagent blend cures at a slower rate
than the other reagent blends tested.
Upon achieving the 7-day cure, aliquots of all twenty-six mixtures were subjected to SPLP
leachate analyses for mercury and manganese. The results of SPLP leachate analyses are
presented in Table 6. A SPLP leachate mercury concentration goal of less than 11 ug/L was
established as an initial performance goal. Review of the data presented in Table 6 reveals
treatment effectiveness varied widely based on reagent type and addition rate for the two soil
composites. Specifically, treatment of the >100 Composite samples resulted in treated leachable
mercury concentrations ranging from 10.5 to 290 ug/L, while treatment of the Visible Composite
samples achieved concentrations of 54.3 to 27,900 ug/L. In general, treatment with Portland
cement either alone or in combination with hydrated lime or ferrous sulfate did not improve
leachable mercury concentrations. In fact, the reported mercury leachate concentrations were
higher in these mixtures then they were in the untreated material. However, treatment performed
with sodium sulfide, in combination with either cement and lime or slag cement and lime did
reduce leachable mercury concentrations.
Review of leachable manganese data revealed that SPLP manganese concentrations were reduced
for all treated materials. These data reveal that all reagent types and addition rates were able to
significantly reduce SPLP manganese concentrations. The leachate manganese concentrations
were low in all reagent mixtures that were evaluated and, with one exception of 36 ug/L, were
always less than 10.6 ug/L. In general, the greater reductions were noted for treatment with
Portland cement alone, although significant reductions were achieved with several of the reagent
mixture designs.
3555i3 5_102 Page 10of28 Iu_vipoNE,., a^�tiNT_�.LSERvZCEs,INC.
_1I PLED TECHNOLOGIES GROLP

Table 5
Preliminary Stabilization Treatment
Mixture Development and Penetrometer Evaluations
Keniron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
KEMRON
SAMPLE
No.
UNTREATED
MATERIAL
TYPE
REAGENT
TYPE
REAGENT
ADDITION
N
WATER
ADDITION
N
PENETROMETER TESTING
(tons/ft2)
Day
1 1
Day
4
Day
7
3555-001
>1.00 Composite
Type 1 Portland Cement
10
10
>4.5
>4.5
>4.5
3555-002
>I00 Composite
Type I Portland Cement
15
15
>4.5
>4.5
>4.5
3555-003
>100 Composite
Type I Portland Cement
20
20
>4.5
>4.5
>4.5
3555-004
>100 Composite
Cement / Sodium Sulfide
15 / 2.5
18
>4.5
>4.5
>4.5
3555-005
>100 Composite
Cement / Sodium Sulfide
15 / 5.0
18
>4.5
>4.5
>4.5
3555-006
>100 Com osite
Cement / hydrated Lime
7.5 / 7.5
20
3.5
>4.5
>4.5
3555-007
>1.00 Composite
Cement / Hydrated Lime
10/10
25
3.5
>4.5
>4.5
3555-008
> 100 Composite
Cement / Lime / Sodium Sulfide
10 / 10/2.5
25
4
>4.5
>4.5
3555-009
>100 Composite
Cement / Lime / Sodium Sulfide
10 / 10 / 5.0
25
3.5
>4.5
>4.5
3555-010
>100 Composite
Slag Cement / Sodium Sulfide
15/2.5
17.5
0
>4.5
>4.5
3555-01 1
>1.00 Composite
Slag Cement / Sodium Sulfide
15 / 5
20
0
>4.5
>4.5
3555-012
> 1.00 Composite
Slag Cement / Lime / Sodium Sulfide
10 / 10 / 5.0
25
1.75
>4.5
>4.5
3555-013
>100 Composite
Cement / Ferrous Sulfate
15 / 3.0
18
2.75
>4.5
>4.5
3555-014
Visible Composite
Type I Portland Cement
10
10
>4.5
>4.5
>4.5
3555-015
Visible Composite
Type I Portland Cement
15
15
>4.5
>4.5
>4.5
35.55-01.6
Visible Composite
Type I Portland Cement
20
20
>4.5
>4.5
>4.5
3555-017
Visible Composite
Cement / Sodium Sulfide
15/2.5
17.5
>4.5
>4.5
>4.5
3555-018
Visible Composite
Cement / Sodium Sulfide
15 / 5.0
20
>4.5
>4.5
>4.5
3555-019
Visible Composite
Cement / Hydrated Lime
7.5 / 7.5
20
3
>4.5
>4.5
3555-020
Visible Composite
Cement / Hydrated Lime
10/10
25
2.25
>4.5
>4.5
355.5-021
Visible Composite
Cement / Lime / Sodium Sulfide
10/10/2.5
25
3
>4.5
>4.5
3555-022
Visible Composite
Cement / Lime / Sodium Sulfide
10 / 10 / 5.0
25
4.25
>4.5
>4.5
3555-023
Visible Composite
Slag Cement / Sodium Sulfide
15/2.5
17.5
0
3.5
>4.5
3555-024
Visible Composite
Slag Cement / Sodium Sulfide
15/5
20
0
2.75
3.75
3555-025
Visible Composite
Slag Cement / Lime / Sodium Sulfide
10/10/5 .0
25
1.75
>4.5
>4.5
3555-026
Visible Composite
Cement / Fen-ous Sulfate
15 / 3.0
18
2.5
>4.5
>4.5
Kemron Environmental Services, Inc.
3555 204.xis Applied Technologies Group

Table 6
Preliminary Stabilization Treatment
Summary of Mixture Development and Leachable Metals analyses
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
KEMRON
SAMPLE
No.
UNTREATED
MATERIAL
I TYPE
REAGENT
TYPE
REAGENT
ADDITION
N
WATER
ADDITION
NO
SPLP METALS
(ug/L)
Manganese
Mercury
Untreated
>100 Composite
-
20
111
3555-001
>100 Composite
Type I Portland Cement
10
10
1.2
275
3555-002
>100 Composite
Type I Portland Cement
15
15
0.76
245
3555-003
> 100 Composite
Type I Portland Cement
20
20
0.89
244
3555-004
>100 Composite
Cement / Sodium Sulfide
15 / 2.5
18
1.3
59.3
3555-005
>100 Composite
Cement/ Sodium Sulfide
1515.0
18
0.93
232
3555-006
>100 Composite
Cement / Hydrated Lime
7.5 / 7.5
20
0.78
290
3555-007
>100 Composite
Cement / Hydrated Lime
10/10
25
0.85
270
3555-008
>100 Composite
Cement / Lime / Sodium Sulfide
1011012.5
25
0.46
14.7
3555-009
1 >100 Composite
Cement / Lime / Sodium Sulfide
10 / 10 / 5.0
25
0.63
10.5
3555-010
>100 Composite
Slag Cement / Sodium Sulfide
15 / 2.5
i 7.5
1.0
108
3555-011
>100 Composite
Slag Cement / Sodium Sulfide
1515
20
2.0
83.5
3555-012
>100 Composite
Slag Cement / Lime / Sodium Sulfide
1011015.0
25
0.77
ill
3555-013
>100 Composite
Cement / Ferrous Sulfate
15 / 3.0
18
4.1
168
Untreated
Visible Composite
-
-
-
82.2
723
3555-014
Visible Composite
Type I Portland Cement
10
10
0.65
2790
3555-015
Visible Composite
Type I Portland Cement
15
15
0.46
3060
3555-016
Visible Composite
Type I Portland Cement
20
20
1.8
3580
3555-017
Visible Composite
Cement / Sodium Sulfide
1512.5
17.5
1.4
2210
3555-018
Visible Composite
Cement / Sodium Sulfide
1515.0
20
36.2
1820
3555-019
Visible Composite
Cement / Hydrated Lime
7.5 / 7.5
20
2.2
2230
3555-020
Visible Composite
Cement / Hvdrated Lime
10/10
25
2.1
2920
3555-021
Visible Composite
Cement / Lime / Sodium Sulfide
10 / 10 / 2.5
25
10.6
54.3
3555-022
Visible Composite
Cement / Lime / Sodium Sulfide
1011015.0
25
8.0
132
3555-023
Visible Composite
Slag Cement/ Sodium Sulfide
1512.5
17.5
1.5
5620
3555-024
Visible Composite
Slag Cement / Sodium Sulfide
1515
20
10.4
27900
3555-025
Visible Composite
Slag Cement / Lime / Sodium Sulfide
10 / 1015.0
25
2.0
103
3555-026
Visible Composite
Cement / Ferrous Sulfate 1
1513.0
18
1.0
1110
Kemmn En,uonmeaal Ser%ices, Inc.
5 208.xis
_ Applied Technologies Group

3.5 C.ANDIDATE MIXTURE EVALUATION
Based on review of the preliminary results, the Client and Kemron selected several candidate
reagent mixtures for each of the composite soil samples for reagent optimization testing. The
reagent mixtures were selected based on the results of SPLP leachate analyses performed during
preliminary testing. Kemron selected the candidate reagent mixtures, which 1) reduced leachable
mercury concentrations, 2) provided good strength and setting properties, and 3) were relatively
cost effective. Specifically, the following reagents and combinations were selected for further
more detailed evaluations designed to optimize reagent selection and addition rates:
• Lonestar Slag Cement
• Lonestar Slag Cement / Lime
• Lonestar Slag Cement / Lime / Sodium Sulfide
• Cement / Lime / Sodium Sulfide
• Cement / Lime / Sodium Sulfide / Ferrous Sulfate
The candidate mixture development is presented in Table 7. This table presents the reagents, the
reagent addition rates and water addition rate used to develop each reagent mixture. All reagent
mixtures were developed in accordance with previously presented protocols. After treatment,
each reagent mixture was allowed to cure for a period of 7 days prior to testing. Upon
completion of the 7-day cure each of the treated candidate reagent mixtures was subjected to a
range of verification analyses, including both physical and chemical characterization testing.
During the curing process, treated mixtures were evaluated for setting and strength properties
through penetrometer strength testing. A review of data in Table 7 reveals that all mixtures,
except two, achieved penetrometer strength values in excess of 4.5 tons/ft2 after 3 to 5 days of
curing. The two remaining mixtures (Lonestar Slag mixtures) had penetrometer strength values
of 1.5 tons/ft2 and 1.0 tons/ft2 after 7 days. These results are consistent with the strength testing
results for the initial mixture assessment. In the initial assessment, slag plus sodium sulfide had
lower strength values. Therefore, this reagent mixture (slag plus sodium sulfide) was not
assessed during candidate mixture development.
Upon achieving the seven-day cure, aliquots of all 20 reagent mixtures were subjected to SPLP
leachate and total mercury and manganese analyses. Specifically, each of the treated mixtures
was submitted to CompuChem Laboratories for the following analytical analyses in accordance
with the referenced test methods:
-�55%�555_102 Page 11 of28 K:-:YROvE1,T%�tONv1 NTALSLR`TCbS, INC.
APPLFED T-_PCF_N0L0G1ES GROUP

Table 7
Optimization Stabilization Treatment
Bound 2 Mixture Development and Penetrometer Evaluations
Keniron Environmental Services, Inc.
Duracell - Lexington Site rFreatabilly Study
ICI1MRON
SAMPLE
No.
UNTREATED
MATERIAL
TYP1i
REAGENT
TYPE
REAGENT
ADDITION
(%
WATER
ADDITION
N
PENETROMETER
TES"f1NG (tons/ft2)
Day
1
Day
3
Day
5
Day
7
3555-027
>I00 Composite
Lonestar Slag
15
15
0
0
0.5
1.5
3555-028
>100 Composite
Lonestar Slag / Lime
10/10
25
1.25
3.5
>4.5
>4.5
3555-029
>100 Composite
Lonestar Slag / Lime / Sodium Sulfide
10/10/2.5
22.5
1.25
3
>4.5
>4.5
3555-030
>100 Composite
Lonestar Slag / Lime / Sodium Sulfide
15 / 10 / 5.0
30
1.25
3.25
>4.5
>4.5
3555-031
> i 00 Composite
Cement / Lime / Sodium Sulfide
5 / 5 / 2.5
17.5
3.25
>4.5
>4.5
>4.5
3555-032
>100 Composite
Cement 1 Lime / Sodium Sulfide
7.5 / 7.5 / 2.5
25
3
4.25
>4.5
>4.5
3555-033
>100 Composite
Cement / Lime / Sodium Sulfide
10/10/2.5
30
3.75
>4.5
>4.5
>4.5
3555-034
> 100 Composite
Cement / Lime / Sodium Sulfide
20 / 10/2.5
35
>4.5
>4.5
>4.5
>4.5
3555-035
> 100 Composite
Cement / Lime / Sodium Sulfide / Ferrous Sulfate
10 / 10 / 2.5 / 2.5
30
2
4
>4.5
>4.5
3555-036
>I 00 Composite
Cement / Lime / Sodium Sulfide / Ferrous Sulfate
20 / 10 / 2.5 / 2.5
40
3
>4.5
>4.5
>4.5
3555-037
Visible Composite
Lonestar Slag
15
15
0
0.5
1
1
3555-038
Visible Composite
Lonestar Slag / Lime
10 / 10
25
2
>4.5
>4.5
>4.5
3555-039
Visible Composite
Lonestar Slag / Lime / Sodium Sulfide
10 / 10/2.5
22.5
2
>4.5
>4.5
>4.5
3555-040
Visible Composite
Lonestar Slag / Lime / Sodium Sulfide
15 / 10 / 5.0
30
3
>4.5
>4.5
>4.5
3555-041
Visible Composite
Cement / Lime / Sodium Sulfide
5 / 5 / 2.5
17.5
3
>4.5
>4.5
>4.5
3555-042
Visible Composite
Cement / Lime / Sodium Sulfide
7.5 / 7.5 / 2.5
25
3.75
>4.5
>4.5
>4.5
3555-043
Visible Composite
Cement / Lime / Sodium Sulfide
10/10/2.5
30
4
>4.5
>4.5
>4.5
3555-044
Visible Composite
Cement / Lime / Sodium Sulfide
20 / 10/2.5
35
1.5
>4.5
>4.5
>4.5
3555-045
Visible Composite
Cement / Lime / Sodium Sulfide / Ferrous Sulfate
10 / 10 / 2.5 / 2.5
30
4
>4.5
>4.5
>4.5
3555-046
Visible Composite
Cement / Lime / Sodium Sulfide / Ferrous Sulfate
20 / 10 / 2.5 / 2.5
40
>4.5
>4.5
>4.5
>4.5
Ken -iron Environmental Services, Inc
3555 209.xis Applied Technologies Group

Parameter
SPLP Mercury and Manganese
Total Mercury and Manganese
Method
EPA Methods 1312/6010B/7470
EPA Methods 6010B/7471
The results of total and SPLP leachate analyses are presented in Table 8. Review of the data
presented in Table 8 reveals that all reagent mixtures resulted in significant reductions of
leachable mercury concentrations when compared to untreated composite samples. Specifically,
treatment of the >100 Composite samples reduced leachable mercury from 111 ug/L in the
untreated composite to less than 19.6 ug/L for all mixtures. Several reagent mixtures, developed
with cement / lime / sodium sulfide, achieved SPLP leachable mercury concentrations of less
than 3.0 ug/L. Treatment of the Visible Composite samples resulted in generally similar results.
Specifically, SPLP leachable mercury was reduced from 723 ug/L in the untreated composite to
less than 130 ug/L in all reagent mixtures. Again, some of the greater reductions in leachable
mercury were achieved for treatment with cement/lime/sodium sulfide, with treated
concentrations of as low as 4.2 ug/L. A relationship between reagent concentration and leachable
mercury was observed for the cement/lime/sodium sulfide reagent mixture in the visible
composite, where the concentration of leachable mercury decreased as the reagent concentration
increased. Relationships between reagent concentrations and leachate mercury concentrations
were not apparent in other composite sample/reagent mixture combinations.
Treatment also resulted in significant reductions in leachable manganese concentrations.
Specifically, treatment of the >100 Composite samples resulted in SPLP manganese
concentrations of less than 5.2 ug/L for all mixtures. This compares to an untreated SPLP
manganese concentration of 20 ug/L for the >100 Composite. Treatment of the Visible
Composite samples also achieved similar reductions. The untreated SPLP manganese
concentration for the Visible Composite was reported as 82.2 ug/L, while treated concentrations
were all below 4.6 ug/L.
Based on review of the results of the optimization testing, the Client selected two candidate
mixtures for further testing on each of the composite soils. The mixtures were selected based on
the results of SPLP leachate analyses performed during the optimization testing. Specifically,
the following reagents and combinations were selected for further more detailed evaluations:
Slag Cement / Lime / Sodium Sulfide
Cement / Lime / Sodium Sulfide
The candidate reagent mixture development is presented in Table 9. This table presents the
reagciits the reagent addltron rates and Neater addition rate used to develop each mixture. All
555i'3555 102 Page 12 of 28 IiE�fRON ENS ONMENT_- L SER�TCES, LTC.
Ap°�IED TEC:LNOLOGEES GROUT

Table 8
Optimization Stabilization Treatment
Round 2 Mixture Development
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
KEMRON
SAMPLE
No.
UNTREATED
MATERIAL
TYPE
REAGENT
TYPE
REAGENT
ADDITION
%)
METALS ANALYSES
Total Metals mg/Kg) I
SPLP Metals (ug/L)
Manganese I
Mercury I
Manganese I Mercury
Untreated
>100 Composite
-
-
20
ill
3555-027
>100 Composite
Lonestar Slag,
15
1,670
916
1.7
7.1
3555-029
>100 Composite
Lonestar Slag / Lime
10/10
1,470
678
2.0
5.8
3555-029
> 100 Composite
Lonestar Slag / Lime / Sodium Sulfide
10/10/2.5
1,210
837
2.5
5.3
3555-030
>100 Composite
Lonestar Slag / Lime / Sodium Sulfide
15 / 10 / 5.0
1,360
777
1.8
19.6
3555-031
>100 Composite
Cement / Lime / Sodium Sulfide
5/5/2.5
752
918
2.6
1.3
3555-032.
>100 Composite
Cement / Lime / Sodium Sulfide
7.5 / 7.5 / 2.5
654
880
2.6
2.0
3555-033
> I00 Composite
Cement / Lime / Sodiurn Sulfide
10/10/2.5
610
693
2.1
9.1
3555-034
>100 Composite
Cement / Lime / Sodium Sulfide
20/10/2.5
585
544
5.2
2.9
3555-035
> 100 Composite
Cement / Lime / Sodium Sulfide / Ferrous Sulfate
10 / 10 / 2.5 / 2.5
615
611
2.1
8.8
3555-036
> I00 Composite
Cement / Lime / Sodium Sulfide / Ferrous Sulfate
20 / 10 / 2.5 / 2.5
601
557
3.8
1.7
Untreated
Visible Composite
-
-
82.2
723
3555-037
Visible Composite
Lonestar Slag
15
1,580
10,700
3.6
7.0
355.5-039
Visible Composite
Lonestar Slag / Lirne
10/10
1,160
10,700
4.6
75.6
3555-039
Visible Composite
Lonestar Slag / Lime / Sodium Sulfide
10/10/2.5
1,070
12,300
1.6
1.7
3555-040
Visible Composite
Lonestar Slag / Lime / Sodium Sulfide
15 / 10 / 5.0
1,990
12,900
1.8
7.1
3555-041
Visible Composite
Cement / Lime / Sodium Sulfide
5 / 5 / 2.5
760
17,500
1.7
130
3555-042
Visible Composite
Cement / Lime / Sodium Sulfide
7.5 / 7.5 / 2.5
707
15,900
3.0
13.7
3555-043
Visible Composite
Cement / Lime / Sodium Sulfide
10/10/2.5
622
12,200
1.1
4.2
3555-044
Visible Composite
Cement / Lime / Sodium Sulfide
20/10/2.5
550
9,020
1.1
6.8
35.55-04.5
Visible Composite
1 Cement / Lime / Sodium Sulfide / Ferrous Sulfate
10 / 10 / 2.5 / 2.5
678
9,590
1.9
4.5
3555-046
Visible Composite
Cement / Lime / Sodium Sulfide / Ferrous Sulfate
20 / 10 / 2.5 / 2.5
572
9,440
1.7
6.9
Keniron Environmental Services, Inc.
3555_212.xis Applied Tecluiologies Group

Table 9
Optimization Stabilization Treatment
Round 3 Mixture Development and Volumetric Expansion
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
KEMRON
SAMPLE
No.
UNTREATED
MATERIAL
TYPE
REAGENT
TYPE
REAGENT
ADDITION
N
WATER
ADDITION
N
Volumetric Expansion (%o)
Experimentally
Determined (t)
Theoretically
Calculated (2)
3555-053
>100 Composite
Cement / Lime / Sodium Sulfide
10 / l0 / 2.5
27.5
66
67
3555-054
>100 Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 2.5
22.5
53
49
3555-055
> 100 Composite
Cement / Lime / Sodium Sulfide
10 / 2.5 / 2.5
22.5
55
54
3555-056
>100 Composite
Lonestar Slag / Lime / Sodium Sulfide
10 / 10 / 2.5
25
62
61
3555-057
>100 Composite
Lonestar Slag / Lime / Sodium Sulfide
10 / 5 / 2.5
22.5
52
51
3555-058
>100 Composite
Lonestar Slag / Lime / Sodium Sulfide
10 / 2.5 / 2.5
20
45
43
3555-047
Visible Composite
Cement / Lime / Sodium Sulfide
10 / 10 / 2.5
25
57
58
:1555-048
Visible Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 2.5
20
46
44
3555-049
Visible Composite
Cement / Lime / Sodium Sulfide
10 / 2.5 / 2.5
20
30
42
3555-050
Visible Composite
Lonestar Slag / Lime / Sodium Sulfide
10 / 10 / 2.5
25
55
64
3555-05 l
Visible Composite
Lonestar Slag / Lime / Sodium Sulfide
10 / 5 / 2.5
20
44
45
3555-052
Visible Composite
Lonestar Slag / Lime / Sodium Sulfide
10 / 2.5 / 2.5
20
49
46
t Volumelm; expansion determined experimentally based on volume measurements pertormed on untreated and treated material.
2 vmumcu is expansion catemarea oasea on me touowmg iornnua: ts= tun%o til t rc) x tu;,, i u,«„)-tl
Il Percent volume increase.
R thy weight ratio of reagent to waste.
Di,, Dry unit weight of in -situ waste.
Dt,,;,t Ihy unit weight of compacted treated material.
Kemron Environmental Services, Inc.
3555 216.x1s Applied Technologies Group

reagent mixtures were developed in accordance with previously presented protocols. After
treatment, each reagent mixture was allowed to cure for a period of 7 days prior to performing
treated analyses. Upon completion of the 7-day cure each of the treated candidate reagent
mixtures was subjected to a range of verification analyses, including both physical and chemical
characterization testing.
Volumetric expansion was measured in the samples as summarized in Table 9. A theoretically
volumetric expansion was also calculated. As indicated in the table, the results of the measured
and the theoretically values were close for most of the samples.
After 7 days of curing, UCS testing was performed as summarized in Table 10. For the >100
composite, the results reveal a strength between 60.1-147.2 pounds per square inch (lb/in2) for
the reagent mixtures with cement/lime/sodium sulfide and a strength of 63.9-169.5 lbs/in2 for the
reagent mixtures with Lonestar slag/lime/sodium sulfide. For the visible composite, the results
reveal a strength between 220.4-288.5 lb/in2 for the reagent mixtures with cement/lime/sodium
sulfide and a strength of 111.1-245.9 lbs/in2 for the reagent mixtures with Lonestar
slag/lime/sodium sulfide.
Upon achieving the 7-day cure, aliquots of all twelve reagent mixtures were subjected to SPLP
leachate and total mercury and manganese analyses. All samples were submitted and analyzed
by CompuChem Laboratories in accordance with previously presented methods.
The results of total and SPLP leachate analyses are presented in Table 11. Review of the data
presented in Table 11 reveals that all reagent mixtures resulted in significant reductions of
leachable mercury concentrations in both soil composites. Specifically, treatment of the >100
Composite samples reduced leachable mercury from 111 ug/L in the untreated composite sample
to 13.9 ug/L or less for all reagent mixtures. The three reagent mixtures, developed with
cement/lime/sodium sulfide, achieved leachable mercury concentrations of 1.7 ug/L or less.
Treatment of the Visible Composite samples resulted in generally similar results. Specifically,
leachable mercury was reduced from 723 ug/L in the untreated to 20.9 ug/L or less in the treated
samples. The most consistent reductions were achieved for treatment with cement/lime/sodium
sulfide, with treated concentrations of 6.1 ug/L or lower reported.
Treatment also resulted in significant reductions in leachable manganese concentrations.
Specifically, treatment of the >100 Composite samples resulted in SPLP manganese
concentrations of 1.7 ug/L or less for all reagent mixtures. This compares to an untreated SPLP
manganese concentration of 20 ug/L for the >100 Composite. Treatment of the Visible
Composite samples also achieved similar reductions. The untreated SPLP manganese
3555/3-55 102 Page 13 of28 KEViRONE\ViRoNT,'\,7F-,\T-u S=RN'IC-=S, NC.
A?P=D 1-tC'_�OLOGLFs GROUP

Table 10
Optimization Stabilization Treatment
Round 3 Mixture Development and Unconfined Compressive Strength
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
KliMRON
SAMPLE
No.
UNTI LEATED
MATERIAL
TYPE
REAGENT
TYPE
REAGENT
ADDITION
N
WATER
ADDPfION
(%)
UCS RESULTS
7 Day
Bulk Density
(lb/I?)
Dry Density
(lb/ft3)
Moisture
Content (%)
UCS
(lb/in')
3555-053
> 100 Composite
Cement / Lime / Sodium Sulfide
10 / 10 / 2.5
27.5
102.2
71.0
44.0
60.1
3555-054
>100 Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 2.5
22.5
101.9
75.7
34.6
146.8
3555-055
>100 Composite
Cement / Lime / Sodium Sulfide
10 / 2.5 / 2.5
22.5
99.4
69.6
42.7
147.2
3555-056
_
>100 Composite
Lonestar Slag / Lime / Sodium Sulfide
10 / 10 / 2.5
25
106.1
74.8
41.9
169.5
3555-057
_
_ > 100 Composite
Loii"iai Sla - / Li ue / Sodium Sulfide
10 / 5 / 2.5
22.5
105.8
74.7
41.6
130.8
3555-058
> 100 Composite
Loncstar Slag / Lime 1 Sodium Sulfide
10 / 2.5 / 2.5
20
107.8
75.0
43.9
63.9
3555-047
Composite
Cement/ Lime / Sodium Sulfide
10 / 10 / 2.5
25
109.5
75.6
44.9
220.4
3555-048
_Visible
Visible Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 2.5
20
109.6
78.7
36.1
279.1
3555-049
Composite
Cement/ Lime / Sodium Sulfide
10 / 2.5 / 2.5
20
110.0
77.2
42.5
288.5
3555-050
_Visible
Visible Composite
Lonestar Slag / Lime / Sodium Sulfide
10 / 1012.5
25
106.5
73.0
459
215.5
3555-051
_
Visible Composite
Lonestar Slag / Lime / Sodium Sulfide
10 / 5 / 2.5
20
108.9
78.3
39.0
245.9
3555-052
Visible Composite
-Lonestar Slag / Lime / Sodium Sulfide
10 / 2.5 / 2.5
20
107.9
75.1
43.6
111.1
Kemron Environmental Services, Inc.
3555 215.xis Applied Technologies Group

Table 11
Optimization Stabilization Treatment
Round 3 Mixture Development and Analytical Testing
Kentron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
KEMRON
SAMPLE
No.
UNTREATED
MATERIAL
TYPE
REAGENT
'TYPE
REAGENT
ADDITION
N
WATER
ADDITION
N
METALS ANALYSES
Total Metals (mg/Kg)
SPLP Metals ug/L)
Manganese
Mercury
Manganese
Mercury
Untreated
>100 Composite
-
-
-
20.0
111
3555-053
> 100 Composite
Cement / Lime / Sodium Sulfide
10 / 10 / 2.5
27.5
542
644
0.36
2.0
3555-054
> 100 Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 2.5
22.5
749
219
2.9
3.2
3555-055
>100 Composite
Cement / Lime / Sodium Sulfide
10 / 2.5 / 2.5
22.5
646
564
0.36
6.1
3555-056
>100 Composite
Lonestar Slag / Lime / Sodium Sulfide
10 / 10 / 2.5
25
1,970
664
0.35
5.4
3555-057
>100 Composite
Lonestar Slag / Lime / Sodium Sulfide
10 / 5 / 2.5
22.5
1,790
640
0.37
11.7
3555-058
_
>100 Composite
Lonestar Slag / Lime / Sodium Sulfide
10 / 2.5 / 2.5
20
1,040
528
1.4
20.9
Untreated
Visible Composite
-
-
-
82.2
723
3555-047
Visible Composite
Cement / Lime / Sodium Sulfide
10 / 10 / 2.5
25
567
12,600
0.45
1.5
:3555-048
Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 2.5
20
492
12,000
0.40
0.61
3555-049
_Visible
Visible Composite
Cement / Lime / Sodium Sulfide
10 / 2.5 / 2.5
20
495
13,400
0.62
1.7
3555-050
Composite
Lonestar Slag / Lime / Sodium Sulfide
10 / 10 / 2.5
25
1,170
9,200
0.37
5.4
3555-051
_Visible
Composite
Lonestar Slag / Lime / Sodium Sulfide
10 / 5 / 2.5
20
1,080
14,000
0.59
6.5
3555-052
_Visible
Visible Composite
Lonestar Slag / Lime / Sodium Sulfide
10 / 2.5 / 2.5
20
883
10,100
1.7
13.9
Kennon Environmental Services, Inc.
3.555 218.xls Applied Technologies Group

concentration for the Visible Composite was reported as 82.2 ug/L, while treated concentrations
were all 2.9 ug/L or less.
Consistent with the second round of treatability testing, the third round of optimization
stabilization treatment provided strong indications that the selected reagents and mixtures
resulted in treated mixtures with significantly improved strength and reduced leachability of both
manganese and mercury.
3.6 OPTIMIZATION TESTING -STAGE 2
Reagent mixtures containing cement/lime/sodium sulfide were assessed during the second stage
of optimization testing. The purposes of this testing were to optimize the addition rate for
sodium sulfide, to assess generation of mercury and sulfide vapor during curing, and to assess
leachability of mercury and manganese with respect to curing time.
In an effort to evaluate off gas characteristics, Kemron performed off gas monitoring during the
second stage of the optimization testing. This testing was performed using three candidate
reagent mixtures for the visible composite and >100 composite samples, respectively, resulting in
a total of six test mixtures. Mixtures of Portland cement, hydrated lime, and sodium sulfide were
the selected reagents. The addition rates are presented in Table 12. Testing was performed in a
glove box with a mercury vapor analyzer (Jerome 431X, .000-.999 mg/m3 Hg, 750 cc/min flow
rate) and a hydrogen sulfide meter being used to monitor the vapors. Air was pumped into the
glove box at a rate of 12 1pm (liters per minute) and extracted at a rate of 10 1pm to ensure a
positive pressure in the glove box. In the sealed glove box, the untreated composite soil and
reagent blend were mixed for five minutes using an electric mixer. After five minutes, the mixer
was turned off and the sample was molded and placed in Ziploc bags. Periodically the mercury
and sulfide vapors in the Ziploc bag were measured during the following five days. Table 13
summarizes the vapor readings.
After 1, 2 and 7 days of curing, samples were shipped to CompuChem for SPLP and total
mercury and manganese analyses. The results of the analyses are summarized in Table 12. After
7 days of curing, the samples were subjected to unconfined compressive strength and falling head
permeability testing as summarized in Table 14 and Table 15.
Review of the data in Table 12 reveals that, as anticipated, the values for total mercury and
manganese did not change significantly through the 7 days of curing. The values determined
after 2 days of caring, however, are significantly different from the results obtained after 1 day
3555,'3555_102 Page 14 of28 :KEMRo-i,,T SE.RVIC'S, Live.
APP=D TECHNOLOGIES GROUP

Table 12
Optimization Stabilization Treatment
Round 4 Mixture Development and Analytical Testing
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatabillty Study
KI MRON
SAMPLE
No.
UNTREATED
MATERIAL
TYPE
REAGENT
TYPF
REAGENT
ADDITION
N
WATER
ADDITION
N
TREATED
MATERIAL plI
S.u)
CURE
TIME
(Days)
METALS ANALYSES
Total Metals (mg/Kg)
SPLP Metals u L
Manganese
Mercury
Manganese
Mercury
Unhealed
Visible Composite
-
-
-
-
-
-
82.2
723
3555-059
Visible Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 5
25
12.6
1
598
12,700
11.3
18,900
2
8.0
13,600
-
-
7
560
8,990
91.4
24.8
3555-060
Visible Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 2.5
25
12.5
1
519
8,030
31.0
4.4
2
8.6
1,230
-
-
7
606
8,920
11.6
3.9
3555-061
Visible Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 1.25
25
12.5
1
557
11,300
5.3
245
2
5.2
27.4
-
-
7
573
10,400
3.9
23
Untreated
>100 Composite
-
-
-
-
-
-
20
111
3555-062
>100 Composite
Cement/ Lime / Sodium Sulfide
10 / 5 / 5
25
12.4
1
602
630
13.2
10,500
2
5.0
3,760
7
756
774
5.7
15.0
3555-063
> 100 Composite
Cement / Lime / Sodium Sulfide
10 / 5 12.5
25
12.3
1
652
528
6.6
19.7
2
4.8
50.9
-
7
557
605
3.2
8.0
3555-064
> 100 Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 1.25
25
12.3
1
612
717
8.4
2.6
2
5.0
6.2
7
563
619
3.4
1.7
Kennon Environmental Services, Inc.
3555 223.xls Applied'recbnologies Group

Table 13
Mixture development and vapor nruniluning evaluations
Kemron Environmental Services, Inc.
Duracell - Lexington Site'1'reatability Study
SAMP1,11
11)
REAGENT
ADDITION
RKM (%)
Hg (PPb)
I12S (PP111)
0 hour (t)
1 hour (2)11.5
hour (2)
4 hours l21
1 w
;Z�Day
0 hour (n)
1. hour lzi
1.5 hour cz>
4 hours Zl
Day 1. R)
Day 4
Dey 5 1
3555-059
Cement / ]-into / Sodium Sulfide
10 / 5 / 5
0.600
NM
0.530
0.091
0.056
0.274
>0.999
<1
NM
<1
<1
<1
<1
<1
3555-060
Ccnnenl / Lime / Sodium Sulfide
10 / 5 / 2.5
>0.999
0.484
NM
0.075
0.26
0.395
>0.999
<1
<1
NM
<1
<1
<1
<1
3555-061
Ccm enl / Lime / Sodium Sulfide
10 / 5 / 1.25
>0.999
0.779
NM
0.116
0.100
0.325
>0.999
<1
<1
NM
<1
<1
<1
<1
3555-062
Cement / Lime / Sodium Sulfide
10 / 5 / 5
>0.999
0.071
NM
0.086
0.186
0.147
>0.999
<1
<1
NM
<1
<1
<1
<1
3555-063
Cement / Lime / Sodiunn Sulfide
10 / 5 / 2.5
>0.999
NM
0.022
0.075
0.092
0.166
0,168
<1
NM
<1
<1
<1
<1
<1
3555-064
Cement / Lime / Sodium Sulfide
1 10 / 5 / 1.25
0.959
0.050
1 NM
1 0.124
1 0.076
0.308
0.063
1 <1
<1
NM
<1
<1
<1
<1
NM: Nut Measutc(I
0): Val- while mixing
('): Vapoia was measured in hcadspac° of zip log back, while sample was cut big
Kemron Environmental Services, Inc.
3555 22I.As Applied Technologies Group

Table 14
Optimization Stabilization Treatment
Round 4 Mixture Development and Unconfined Compressive Strength
Kemrou Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
KL'MRON
SAMPLE
No.
UNTREATED
MATERIAL
TYPE
REAGENT
TYPE
REAGENT
ADDITION
%
WATER
ADDITION
(%
UCS RESULTS
7 Day
Bulk Density
(Ib/fe)
Dry Density
(Ib/f?)
Moisture
Content %)
UCS
(lb/ir1)
3555-059
Visible Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 5
25
105.5
72.7
45.2
138.4
3555-060
Visible Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 2.5
25
106
72.5
46.2
171.1
3555-061
Visibie Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 1.25
25
106.4
73.2
45.3
167.9
3555-00'2
> 1010 Composite
Cement / Linre / Sodium Sulfide
10 / 5 / 5
25
104.8
71
47.6
131.8
3555-063
>100 Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 2.5
25
103.1
72.2
42.8
173.2
3555-064
>100 Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 1.25
1 25
102.1
71.8
42.2
149.G
Keturon Environmental Services, Inc.
3555 '222.xls Applied Tecbnologies Group

Table 15
Treated Materials
Summary of Falling Head Permeability Testing
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatabilty Study
SAMPLE
HYDRAULIC CONDUCTIVITY
Moisture
Bulk
Dry
Permeability
ID
Content (%)
Density (lbs/ft')
Density (lbs/ft')
(cm/sec)
3555-059
46.9
106.3
72.4
5.9 x 10-9
3555-060
46.9
106.6
72.6
1.8 x 10-8
3555-061
47.2
107.9
73.3
4.5 x 10-8
3555-062
45.4
102.7
70.6
8.7 x 10-8
3555-063
45.8
105.6
72.4
1.5 x 10-8
3555-064
30.3
104.8
80.4
3.3 x 10-'
Kemron Environmental Services, Inc.
3555 224.x1s Applied Tecbnologies Group

and 7 days of curing. There is no clear explanation for the inconsistency but, in light of the small
size of soil samples used in mercury analysis (typically 0.7 to 0.5 grams), may be associated with
systematic variations in homogenization, sampling procedures, and chemical analyses. With the
exception of the Visible Composite sample solidified with cement 10%/lime 5%/sodium sulfide
5%, the SPLP leachate results for manganese after 7 days of curing reveal a significant decrease
when compared to 1 day of curing. For SPLP leachate mercury, a decrease is detected in all the
samples after 7 days of curing when compared to the day 1 results. This indicates that time may
be a factor in how strongly manganese and mercury are bound to the solid matrix.
It is noted that for the Visible Composite sample solidified with cement 10%/lime 5%/sodium
sulfide 5% and the >100 Composite sample solidified with cement 10%/lime 5%/sodium sulfide
5%, much higher SPLP leachate mercury values were determined after 1 day of curing than the
values for untreated material. Even though the samples had been homogenized, there is still the
possibility of mercury concentration variations throughout the sample. Especially in the visible
composite, the possibility for higher mercury concentrations in some areas of the sample is
possible, resulting in inconsistent results.
Note that, in Kemron's experience, analytical testing at relatively short cure times often exhibits
significant variability. As part of the review by the Client of the laboratory data sheets generated
by CompuChem, it was found that the pH values reported for the SPLP leachates were much
lower than expected. Many pH values were less than 3 even though, based on the reagent
mixtures used and previously reported SPLP leachate pH values, most or all pHs should be
greater than 11. This discrepancy may be associated with problems encountered during the
leachate testing and may explain why the SPLP results were erratic. It is suggested that the SPLP
data generated during this phase of the treatability testing be used with caution.
Based on review of the data summarized in Table 12, Kemron and the Client outlined an
additional round of replicate testing. Table 16 summarizes the second round of cure time testing
and the results of the treated analyses performed for cure times of 1, 2 and 7 days. This data
reveals that as expected the values for total mercury and manganese did change substantially
through 7 days of curing. For both samples the SPLP leachate results for manganese after 7 days
of curing reveal a decrease when compared to 1 day of curing. Although all manganese SPLP
leachate results were low with the highest being 3.8 ug/L. For SPLP mercury, a decrease was
detected in all the samples after 7 days of curing as compared to the day 1 results. The highest
reported mercury SPLP leachate result for day 1 was 16 ug/L, with the highest result for day 2
and 7 being 1.6 ug/L. This indicates that time may not be as significant a factor in how strongly
manganese and mercury are bound to the solid matrix. For both samples lower SPLP metals
concentrations urere deter wined after treatment as compared to the untreated samples.
3-;553»j 102 Pa(ze 15 of28 P-:mkoNE2vtiL2oW1P ,_4L.8ERVICEs, LAC.
APP=D T=-L�30Lo=s GROUP

Table 16
Optimization Stabilization Treatment
Hound 5 Mixture Development and Analytical Testing
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
KHMRON
SAMPLE'
No.
UNTREATED
MATERIAL
TYPE
REAGENT
TYPE
REAGENT
ADDITION
N
WATL'R
ADDITION
(%
CURE
TIME
(Days)
TREATED
MATERIAL pfI
(s.0
METALS ANALYSES
Total Metals (mg/Kg)
SPLP Metals u
Man anese
Mercury
Manganese
Mercury
Unfrcaled
Visible Composite
-
-
-
-
82.2
723
3555-065
Visible Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 2.5
25
1
12.72
514
10,200
3.9
3.0
2
12.59
494.0
9,550
0.97
1.2
7
12.49
611
16,600
2.1
0.8
Untreated
; 100 Composite
-
-
-
-
-
20
111
3555-066
> 100 Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 2.5
25
1
12.62
509
708
3.9
16
2
12.53
572.0
599
0.68
1.6
7
12.31
1 545
1 977
1.4
1.2
- Not testc(I
Kemron Environmental Services, Inc.
3555 233.xis Applied Technologies Group

- Mercury vapors were released during the curing process as indicated in Table 13. At some times
concentration of mercury in the headspace in the Ziploc bags exceeded 1.0 ppb (0.008 mg/m3),
with the higher concentrations of mercury vapor being present at the start (time = 0 hour) and the
end (time = 5 days) of the vapor monitoring. The results of the headspace monitoring are not
comparable to conditions in ambient air since mercury vapors monitored during the headspace
testing were maintained in a closed container without dilution. Significant dispersion/mixing
would be expected in the field since the ambient air is constantly being replenished. Hydrogen
sulfide was not detected above the 1 ppm (1.5 mg/m3) monitor detection limit.
Table 14 summarizes the results of the UCS testing performed on the six reagent mixtures
indicating only small variations in the strength when comparing the three reagent mixture designs
for each of the two composite soils. The lowest strength measured for the visible composite was
138.4 pounds per square inch (lb/in2) and the highest strength was 171.1 lb/in 2. For the >100
composite the lowest UCS value was 131.8 Wine and the highest was 173.2 lb/in2.
The falling head permeability results presented in Table 15 indicated very low permeability
values for all six reagent mixtures. The lowest permeability value was noted for the Visible
Composite sample solidified with cement 10%/lime 5%/sodium sulfide 5% which had a
permeability of 5.9x 10-9 cm/sec, and the remaining samples had permeability values in the range
of 1.5-8.7x 10-8 cm/sec.
3.7 MULTIPLE EXTRACTION PROCEDURE EVALUATIONS
Based on data generated from the stabilization testing, the Client selected two candidate reagent
mixtures for Multiple Extraction Procedure (MEP) testing. This testing was intended to assess
Ion —term performance of the selected reagent blends by assessing the performance of the
stabilized soil and quantitatively determining the rate at which mercury leached from the
stabilized soil. The selected reagent blends were Cement/Lime/Sodium Sulfide blends at a mix
ratio of 10%/5%/2.5% and 10%/5%/1.25%, respectively. The candidate reagent mixture
development is presented in Table 17. This table presents the reagents, the reagent addition rates
and water addition rate used to develop each mixture. All reagent mixtures were developed in
accordance with previously presented protocols. After treatment, each reagent mixture was
allowed to cure for a period of 7 days prior to performing treated analyses. Upon completion of
the 7-day cure, each of the treated candidate reagent mixtures was subjected to a range of
verification analyses, including both physical and chemical characterization testing.
555 3555_102 Page 16 of28 IiEvRONE-N\ RONMENTALSERVICES, LC.
APP?1rD TECIENTOI OG1ES GROUP

Table 17
Optimization Stabilization Treatment
Round 5 Mixture Development For Multiple Extraction Procedure, Penetrometer and Unconfined Compressive Strength
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
I(I MRON
SAMPLE,
No.
UNTREATE1)
MATERIAL
TYPE
REAGENT
TYPE
REAGEN'r
ADDITION
(%)
WATER
ADDITION
(%)
PENETROMETER
UCS RESULTS
I Day
4Day
7Day
(ton/I12)
(ton/ft2
UCS
(lb/in2)
3555-06/
Visible Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 2.5
25
4.0
>4.5
143 / 141
3555-068
Visible Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 1.25
25
3.5
>4.5
127 / 143
3555-069
> 100 Com osite
Cement / Lime / Sodium Sulfide
10 / 5 / 2.5
25
3.5
>4.5
152 / 153
3555-070
> 100 Composite
Cement / Lime / Sodium Sulfide
10 / 5 / 1.25
25
3.0
>4.5
148 / 139
Kemron Environmental Services, Inc.
3555 2.30.x is Applied ,rechnologics Group

To assess variability in the stabilization process, four reagent mixtures were prepared. Each
mixture was compacted into various molds as necessary for the MEP. Mold size varied from as
small as 25 grams to approximate 400 grams. The remaining treated soil was packed in 3x6 inch
molds for falling head permeability testing. During the curing process, treated soils were
evaluated for setting and strength properties employing penetrometer strength testing. A review
of data in Table 17 reveals that all mixtures achieved penetrometer strength values in excess of
4.5 tons/ft2 after 4 days of curing.
After 7 days of curing UCS testing was performed on two of the four samples prepared for each
reagent mixture. The two remaining samples for each mixture were prepared as bulk samples
(not crushed) and subjected to the extraction sequence as an uncrushed cylinder. The other two
samples subjected to UCS testing were crushed using a mortar and pestle. To minimize the
potential for volatilization of metallic mercury, the stabilized soil and appropriate reduction
equipment was refrigerated to 4°C prior to particle size reduction. The crushed sample was
sieved through a 9.5 mm (0.375 inch) standard sieve. Crushed samples from each of the four
mixture designs were sampled in triplicate and analyzed for total mercury (Table 18).
After the 7 days of curing, 16 soil samples were subjected to SPLP leachate performance testing
in accordance with a multiple extraction testing procedure provided in the Treatability Study
Work Plan. The procedure was performed using two separate series of tests. In one series the
same SPLP extraction fluid was used throughout the study, exposing it to fresh soil samples after
each 24-hour period (tests Al through A4). In the second series the same treated soil samples
were employed while being exposed to fresh SPLP extraction fluid after each 24 hour period
(tests Al through H1). The extraction fluid used for the testing was prepared in accordance with
SW-846 Method 1312 (SPLP test) extraction fluid # 1, which is appropriate for the simulation of
precipitation in areas east of the Mississippi River. To assure good contact between the sample
and the extraction liquid, the samples were placed on a shaker table set at a speed of
approximately 50 rounds per minute (rpm) for 24 hours. Following extraction, the samples were
segregated into a liquid and solid phases by filtering through a glass fiber filter. At the
conclusion of each of the extraction steps, extraction fluid was retained for analysis of total
mercury, with 10% of the samples being tested in duplicate to assess the precision of the analyses
(Tables 19 and 20). The pH was measured for each extraction fluid sample collected.
Total mercury concentrations in Table 18 are, with few exceptions, very consistent for the
triplicates of each sample. For the visible composite samples, the total mercury concentrations
ranged from 7,380 to 11,200 mg/Kg. As anticipated, for the >100 composite samples the total
mercury concentrations are much lower, ranging from 634 to 2,010 mg/Kg. The variations
within one mixture might indicate that there is heterogeneity in concentrations of mercury in the
355513555_102 Page 17 of 28 KEviRoNE!NVaO'.NMENT_kL SERVICES, LNC.
APP=-D TECILNOLOGIES GROUP

Table 18
Total Mercury Data
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
KEMRON
SAMPLE
No.
DATE
SAMPLE
DESCRIPTION
Results
Mercury (mg/kg)
3555-067-A
07/26/02
Visible Comp. w/Cement 10 %, Lime 5 %, Sodium Sulfide 2.5 %
91700
3555-067-B
07/26/02
9,180
8,18()
3555-067-C
07/26/02
3555-068-A
07/26/02
Visible Comp. w/Cement 10 %, Lime 5 %, Sodium Sulfide 1.25 %
11,200
3555-068-B
07/26/02
11,200
3555-068-C
07/26/02
7,380
3555-069-A
07/26/02
> 100 Comp.w/ Cement 10 % Lime 5 % Sodium Sulfide 2.5 %
660
3555-069-B
07/26/02
2,010
3555-069-C
07/26/02
689
3555-070-A
07/26/02
> 100 Comp.w/ Cement 10 %, Lime 5 %, Sodium Sulfide 1.25 %
676
3555-070-B
07/26/02
634
3555-070-C
07/26/02
953
Kemron Environmental Services, Inc.
3555 234.xis Applied Teclinologies Group

n
Table 19
hs Using Fresh Extraction Fluid of Same Solid Phase
pmron Environmental Services, Inc.
cell - Lexington Site Treatablllty Study
Results I
Results
131)
Extraction 03 Cl
Extraction #4 (D1)
Extraction #5 (El
Extraction #6 (F1)
Extraction #7 G l Extraction #8 I31
action
ference
Mercury
(ug/I)
Fraction
Difference
Mercury
(ug/1)
Fraction
N61erence
Mercury
I(ug/1)
Fraction
Difference
Mercury
(ug/1)
Fraction
Difference
Mercury
(ug/1)
Fraction
Difference
Mercury
(ug/1)
Fraction
Difference
0.3
5.7
0.8
1.7/2.3
0.4
1.5
0.8
1.6
1.1
3.7/4.8
2.7
2.0
0.5
0.5
1.8/5.2
0.8
1.9
0.5
1.4
0.7
12.1
0.8
7.8
0.5
0.2
1.7
0.3
0.9
0.6
1.2
1.3
1.6
1.3
0.67/0.87
0.5
0.9
1.2
0.5
0.6
0.4
0.7
1.2
0.43/0,32
0.6
0.4
1.1
1.2
2.8
0.4
0.3
0.4
2.9
0.6
1.4
0.6
I.1
0.8
5.2
4.6
5.1
1.0
2.8
0.5
0.4
1.7
0.2
1.9
1.1
2.0
1.1
3.2
1,6
3.1
1.0
3.5
1.1
0.4
1.3
0.2
1.9
1.5
1.4
0.7
3.4
2.4
5.6
1.6
4.4/4.0
0.8
0.2
2.4
OA
0.7
0.3
0.8
1.1
1.9
2.3
3.3
1.7
0.5
0.1
0.6
0.5
0.3
13
2.6
2.0
1.5;5
�_
7.3
1.3
1 0.1
0.3
0.3
0.4
1.5
0.3
1.5
1.4
1.6
1.1
5.8
3.7
33
1 0.6
2.1
0.
18.0
4.3/3.8
0.0
4.9
1.1
10.2
2.1
2.21
1.9
2.4
0.4
2.1
0.9
2.9
23.4
62¢j
l.0
1.0
7.9
3.3
0.2
6.9
2.1
73
1
MIZ `x1
2.6
1 3.0
1 0.1
1 1.5
0.5
2.4
0.6
0.1
2.8
4.7
0.6
0.2
6.5
11.4
1.2
0.2
1.7
1.4
7.5
2.7
0.2
4.2
2.2
5.3
1.2
29.3
1 5.5
1
0.8
1
1.0
9.9
2.5
0.0
2.7
1.1
2.0
0.7`;19:8,;
9.9
6.3
0.3
9.4
1.5
0.8
}' S $, F`
2.4
?� k..,
2.9
` E .):;
1.8sk;]:75,1)
2
2.l:3s'_.
0.3
0.8
5.3
2.6
0.1
4.S/1.1
1.1
2.3
0.8
5.6
2.4
1.9
0.3
1.3
0.7
5.1
2.2
0.1
3.6
1.6
1.3/1.2
0.3
0.7
0.6
0.3
0.4
0.
1.1
5.3
5.8
0.8
13.7
1.722A'
0.9
2.3
41=3:4 `,
0.3
w 8
0.8
.concentration is increasing
Kemron Environmental Services, Inc.
Applied Technologies Group

Table 20
Multiple Extractions Using Same Extraction Fluid of Fresh Solid chase
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
Results
Extraction Al
Extraction A2
Extraction A3
Extraction
A4
KEWRON
SAMPLE
No
SAMPLE
DESCRIPTION
Mercury
(ug/1)
Mercury
(ug/1)
Fraction
Difference
A2/A1
Mercury
(ug/1)
Fraction
Difference
A3/A2
Mercury
(ug/1)
Fraction
Difference
A4/A3
3555-067-C
Visible Comp. w/Cement 10 %, Lime 5 %, Sodium Sulfide 2.5 %
Mjfi
2.5
0.1
8.0
3.2
9,8
1.2
3555-068-C
Visible Comp. w/Cement 10 %, Lime 5 %, Sodium Sulfide 1.25 %
9.3
1.4
0.2
8.9
6.4
5.0
0.6
3555-069-C
> 100 Comp.w/ Cement 10 %, Lime 5 %, Sodium Sulfide 2.5 %
3.2
4.8
0.1
3.8
0,8
3555-070C
> 100 Comp.w/ Cement 10 %, Lime 5 %, Sodium Sulfide 1.25 %
il
2.8
2.0
0.7
3.0
1.5
4.2
1A
Average Value
16.0
24.0
2
5.7
3555-067-t�C
�'isibia C:nm wlCemcnt 10 %, Lime 5 %, Sodium Sulfide 2.5 "/a
1.1
0.1
i.4
4.0
4.6
111
3555-068-DC
Visible Com , w/Cement 10 °/", Lime 5 %, Sodium Sulfide 1.25 %
1.1
0.1
5.8
5.3
3.8
0.7
3555-0694DC
> 100 Comp.w/ Cement 10 %, Lime 5 "/o, Sodium Sulfide 2.5 %
1.3
9.3
0.3
7.2
0.8
3555-070-DC
> 100 Comp.w/ Cement 10 %, Lime 5 %, Sodium Sulfide 1.25 %
2.6
0.75
0.3
3.8
5.1
2.9
0.8
3555-067-S
Average Value
16.2
9.4
5.8
4.6
Visible Comp. w/Cement 10 %, Lime 5 %, Sodium Sulfide 2.5 %
10.2
0.5
6.1
0.6
7.5
1.2
3555-068-S
Visible Comp. w/Cement 10 %, Lime 5 %, Sodium Sulfide 1.25 %
3.5_
% a
5.2
7.3
0.4
?i ?r _ ,
3.9
3555-069-S
> 100 Com .w/ Cement 10 %, Lime 5 %, Sodium Sulfide 2.5 %
2.4/2.6
28.8
1 9.5
0.1
5.8
0.6
3555-070-S
> 100 Com .w/ Cement 10 %, Lime 5 %, Sodium Sulfide 1.25 %
1.8
5.6
1 3.1
2.0
0.4
3.0
1.5
3555-067-DS
Average Value
6.6
26.5
.2
11.2
Visible Com . w/Cement 10 %, Lime 5 %, Sodium Sulfide 2.5 %
8.3/8.4
1.9
2.1
0.1
9.4
4.5
3555-068-DS
Visible Comp. w/Cement 10 %, Lime 5 %, Sodium Sulfide 1.25 %
TI
2.1
3.0
0.5
3555-069-DS
> 100 Comp.w/ Cement 10 %, Lime 5 %, Sodium Sulfide 2.5 %
3.3
40.9
11.5
0.1
7.2
0.6
3555-070-DS
> 100 Comp.w/ Cement 10 %, Lime 5 %, Sodium Sulfide 1.25 %
3.4
5.4
2.0
0.1
2.2
1.1
Average Value
5.5
46.0 1
1 14.8
1
10.5
Duplicate samples are indicated as 2.412.6
Fraction Difference is Average Fractional Difference
Fraction Difference values that are less than 1 indicate the concentration in the extract is decreasing, while values greater than I indicate that the concentration is increasing
Shaded cells indicate that the extract concentration exceeds the 11 ug/L leachate performance standard
S: Solid samples
DS: Duplicate Solid Samples
C: Crushed Samples
DC: Duplicate Crushed Samples
Kemron Environmental Services, Inc.
3555 235.xis Applied Technologies Group

solid matrix. This is not surprising considering that a sample size of 0.5 to 0.7 grams is used for
the testing total mercury in a solid matrix.
A review of Table 19 reveals that for the crushed samples, SPLP leachate mercury values
generally decreased with subsequent extractions (average extraction #1 value 16.1 ug/L vs.
average extraction #8 value 2.4 ug/L). For most crushed samples (58 of 61 samples), mercury
concentrations were below the treatment criterion of 11 ug/L after the initial extraction.
Furthermore, after the initial extraction, the maximum mercury SPLP leachate concentration was
17.0 ug/L. For the crushed samples, there was little difference in performance observed between
the Visible Mercury Composite samples and the >100 Composite samples. Specifically, the
average concentration for all extractions involving the crushed Visible Mercury Composite
samples was 5.9 ugfL while the average concentration for all extractions involving the crushed
>100 Composite samples was 3.6 ug/L.
For the solid samples, more variability was noted and more samples exceeded the 11 ug/L
treatment criterion (41 of 64 samples). The maximum mercury SPLP leachate concentration of
335 ug/L was reported in the second extraction, with a reported SPLP leachate concentration of
only 4.0 ug/L, for that same sample in the third extraction. Unlike the crushed samples, there was
considerable difference observed between the Visible Mercury Composite samples and the <100
Composite samples. Specifically, the average concentration for all extractions involving the
solid Visible Mercury Composite samples was 38 ug/L, while the average concentration for all
extractions involving the solid >100 Composite samples was 4.7 ug/L. Of the solid samples in
which the mercury SPLP leachate concentration exceeded the 11 ug/L criterion, 5 were >100
Composite samples (with four of those five exceedances occurring in Extraction #2) and 18 were
Visible Mercury Composite samples.
In general, higher mercury concentrations in the SPLP leachate were noted for the samples
developed using the solid Visible Mercury Composite samples. This may be a result of the
increased heterogeneity of visible mercury composite material or the presence of elemental
mercury. For most of the samples, a fairly good reproducibility was noted in the results obtained
from duplicates analyses.
As noted, the mercury SPLP leachate concentrations in the crushed samples overall are lower
than for the same samples extracted as solid samples. This phenomenon was particularly true for
the Visible Mercury samples. While the exact cause of this phenomenon is not known, it was
hypothesized prior to testing that since the surface area is larger for the crushed samples the
tendency would be the opposite what was measured due to better contact between the sample and
the extraction liquid. The result however may indicate that 1) it is not until the samples come in
contact with the extraction fluid and the sodium sulfide solubilizes slightly that the sodium
555i>>j5_102 Page 18 of 28 PE-mRON ENZ,TRONTiENT.�L SERVICES, INC.
APPLIED TECHNOLOGmiS GROUP

sulfide can react completely with the mercury and, thereby, reduce its' mobility, or 2) the
buffering of the extraction fluid associated with the crushed samples is higher and the increased
buffering reduces the mobility of mercury in the fluid.
A review of Table 20 reveals that the mercury SPLP leachate concentrations, with only four
exceptions, are lower than 11 ug/L after two extractions (28 of 32 samples were below the
criterion). In contrast to the samples treated in series Al through H1, there is no clear trend in
mercury concentrations from the samples treated in series Al through A4. However, it is again
noted that the crushed samples tended to perform better than did the solid samples. Specifically,
for crushed samples, the mercury SPLP leachate concentration did not exceed the 11 ug/L
criterion in any sample (16 of 16 samples were below the criterion).
The falling head permeability results for the four mixtures presented in Table 21 indicate very
low permeability values for all reagent mixtures. The lowest permeability value was noted for
the Visible Composite sample solidified with cement 10%/lime 5%/sodium sulfide 2.5% which
had a permeability of 2. Ix 10-9 cm/sec, and the remaining samples had permeability values in the
range of 3.6 x10-7 cm/sec to 4.5xl0-8 cm/sec.
The pH values measured in the samples after filtration are summarized in Table 22. All of the
leachate pH values measured after filtration were greater than 10.9. This is consistent with the
pH values anticipated for mixtures containing cement and lime. The overall tendency in pH
values for the Al through H1 series samples was that the monolith samples and their duplicates
have lower pH values than the crushed samples. However, after the eight extraction sessions the
difference between the monolith and the crushed samples pH values are less significant than in
the beginning. For the A2 through A4 series samples, where the leachate remains but new solid
material is exposed in each step, the pH values are, in general, increasing over time.
355513555102 Pane 19 of 28 K:-i-ti1RoN EN�=-IN1IENTAL SEER'VICEs, LAC.
4PP=D TnC_n_VOLooiEs GROUP

Table 21
Optimization Stabilization Treatment
Summary of Falling Head Permeability Testing
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
SAMPLE
HYDRAULIC CONDUCTIVITY
Moisture
Bulk
Dry
Permeability
ID
Content
Density (lbs/ft')
Density (lbs/ft')
(cm/sec)
3555-067
46.9
108.0
73.5
2.1 x 10"9
3555-068
45.0
104.9
72.4
3.6 x 10"'
3555-069
46.1
105.8
72.4
4.5 x 10-'
3555-070
43.3
97.7
68.2
9.3 x 10-9
(1) Moisture Content determined in accordance with ASTM D2216 (dry weight basis)
Ke=on Envronmental Sen-ices, Inc.
3555_229.xis Applied Technologies Group

Table 22
Multiple Extraction Evaluations
Material pH EPA Method 9045
Kemron Environmental Services, Inc -
Duracell -Lexington Site Treatability Study
SAMPLE ID
Sample Size
(g)
Al
B1
C1
D1
E1
F1
G1
H1
pH (s.u)
750 mL
pH (s.u)
250 mL
pH (s.u)
250 mL
pH (s.u)
250 mL
pH (s.u)
250 mL
pH (s.u)
250 mL
pH (s.u)
250 mL
pH (s.u)
250 mL
3555-067 S
251.2
11.82
11.76
11.72
11.72
11.42
11.35
11.28
10.88
3555-067 DS
247.5
11.98
11.64
11.71
11.75
11.41
11.39
11.21
10.90
3555-067 C
250.7
12.67
11.91
11.88
11.86
11.69
11.64
11.45
11.42
3555-067 DC
249.9
12.50
11.98
11.90
11.90
11.79
11.67
11.46
11.29
3555-068 S
248.1
11.82
11.62
11.71
11.69
11.36
11.25
11.00
10.81
3555-068 DS
247.9
11.61
11.65
11.59
11.53
11.29
11.11
10.94
10.77
3555-068 C
250.2
12.67
11.91
11.77
11.63
11.57
11.26
11.24
11.23
3555-068 DC
250.8
12.63
11.93
11.88
11.80
11.62
11.37
11.21
11.25
3555-069 S
247.4
11.96
11.79
11.77
11.73
11.52
11.43
11.21
11.08
3555-069 DS
247-3
11.96
11.75
11.70
11.67
11.55
11.37
11.06
10.95
3555-069 C
250.0
12.57
11.97
11.92
11.81
11.69
11.43
11.32
11.28
3555-069 DC
250.0
12.56
11.82
11.81
11.77
11.75
11.41
11.27
11.27
3555-070 S
248.2
11.76
11.75
11.69
11.68
11.34
11.05
10.77
10.45
3555-070 DS
247.1
11.88
11.80
11.69
11.67
11.32
11.54
11.21
11.07
3555-070 C
250.1
12.42
11.81
11.80
11.86
11.51
11.62
11.37
11.28
3555-070 DC
250.2
12.50
12.01
11.93
11.90
11.47
11-29
11.28
11.22
SAMPLE ID
Sample Size
g
A2
A3
A4
pH (s.u)
375 mL
pH (s.u)
250 mL
pH (s.u)
125 mL
3555-067 S
75
11.71
:--- - -
-
55-06
35 7 DS
75
11 70
:
3555-067 S
5 0
-
11.94
- 067 DS 3555
50
11,63
..12.04
55-067S 35
5 2
3555-067 DS
2 5
11.85
3555-068 S
75
11.81
3555- 68 S 0 D
75
11.72
3555-068 S
50
11.85
555-0 8 3 6 DS
50
1 69 1.
3555-068 S
25
= == ----
12.11
3555-068 DS
25
............:::..::::.:::.........
11.94
3555 0 9 S
75
a..,.o.......
3555-069DS
75
11.75
--
-
3555 069 S
50
11.82 e: •::::: -
35 55-069 DS
50
_
1 .87 - -
1
3555-069 S
-
25
--
"- =_ 12.16
-__---_-_`
- o
3555-069 DS
5 2
:._�-::.::
-- 12.10
3555 070 S
75
1.ss
=_ -_-__-___
DS
75
11.30
_
13555-070
55-0 35 70 S
50
11.64
--0
35.,5 70 DS
-
50
-
11.54
3555-070 S
25
12.09
3555-070 DS
25
12.14
S: Solid samples
DS: Duplicate Solid Samoles
C: Gushed Samples
DC: D ;oiicaie Crushed Sampies
SAMPLE ID
Sample Size
g
A2
A3
A4
pH (s.u)
375 mL
pH (s.u)
250 mL
pH (s.u)
125 mL
3555-067 C
75
12.53
3555-067 DC
75
12.54
- ` ' =
3555 067 C
50
12.
3 5-067 DC
55
50
12.
355506 7 C
25
12.4
1
3555-067 DC
2 5
•••12.45
12.49
3555-068 C
75
3555-068 DC
7 5
12.44
3555-068 C
50
3555-068 DC
50
. -
12.35
=
.....1..2...33.........
3555 068 C
25
3555-068 DC
25
12.37
3555-069 C
75
-:-�k�=:z:�zc:
3p55-069DC
75
12.30
�::.11.
-55-0 9
35 6 C
-0
5
7:•
1.97
3555-069DC
50
12.23
3555-069 C
2 5
-
3555-069DC
25
12.34
3555-070 C
75
---
3555-070 DC
75
:.:1.1.70 :
vi?:ti?•
-
355555-070 C
-
50
n;%�:'�;:
:off•+x.-::::+::
3555-070 DC
50
12.02
3555- 70C
0
2 5
12.25t�
3555-070 DC
25
12.32
3555 227.xls
Kemron Environmental Services, Inc.
Appiied Technologies Group

4.0 PHASE III: CHEMICAL OXIDATION SCREE\ZNG
4.1 OVERVIEW
The chemical oxidation phase of treatability testing was performed to evaluate the effectiveness
of permanganate, persulfate, and hydrogen peroxide as chemical oxidants for the treatment of
volatile organic compounds in site soils and shallow groundwater. This treatment technology
was identified as potential remedial alternative due to the ability to oxidize certain organic
contaminants. Chemical oxidation has proven effective at reducing a range of organic
contaminants, including volatile organics, semi -volatile organics, and organic pesticides. This
technology was identified due to its ability to 1) reduce concentrations of the primary organic
constituents of concern, 2) be applied using either in -situ or ex -situ treatment approaches, and 3)
its flexibility to be used either as a primary treatment technology or as a pretreatment approach.
4.2 TECHNOLOGY DESCRIPTION
In -situ chemical oxidation is a proven method for remediation of contaminated soil, sludge and
ground water. Oxidation is the process by which a system becomes less associated with its
electrons. Reduction is the corresponding gain of electrons that occurs concurrently with
oxidation. Oxidation and reduction occur together in a Redox reaction, which results in the
breakdown (oxidation) of organic compounds. Note that, due to the complex nature of a
contaminated soil system, it is impossible to define the specific chemical reactions occurring
during the redox process.
For the purposes of this study, Kemron elected to evaluate in -situ chemical oxidation approaches.
In -situ chemical oxidation can be applied using a variety of different chemical oxidizers. The
advantages of using chemical oxidation remediation include:
• Relatively inexpensive treatment equipment
• The contaminated areas can be treated without disturbing above -ground structures
• Can be used as primary treatment approach or as a pretreatment approach in conjunction
with other remedial technologies.
• Effective chemical oxidation treatment successfully reduces the total concentrations of
the organic constituents of concern.
355513555_102 Page 20 of 28 K.EiviRo'IN EArvao,,'IvmF_N: AL SERN7cEs, Nc.
APPLED Trc-:rN'oLOGIEs GROUP

There are two principal methods of injecting the oxidants into the soil. The first is a method in
which the oxidant is injected into the soil in conjunction with ground water extraction. The
extraction creates negative pressure causing the oxidant to permeate through the contaminated
soil more rapidly. In the second method the oxidant is injected without any corresponding
ground water extraction. Rather the oxidant is allowed to permeate through the contaminated
soil through natural ground water flow and chemical dissolution. In either case, monitoring wells
are frequently used to track the movement of the oxidation reagent.
4.3 CHEMICAL OXIDATION MIXTURE DEVELOPMENT
Kemron evaluated the effectiveness of four chemical oxidants. Specifically, the oxidants
selected included potassium permanganate, sodium permanganate, sodium persulfate, and
hydrogen peroxide. To evaluate potassium permanganate and sodium persulfate, Kemron
developed one mixture using each oxidant in evaluating oxidation in groundwater only. Further,
Kemron developed a total of 10 mixtures using potassium permanganate and sodium persulfate
at various addition rates for the evaluation of treatment performed using groundwater and soil
together. Sodium permanganate was evaluated when treating groundwater spiked with the
constituents of concern. Finally, to evaluate hydrogen peroxide as an oxidizer, Kemron
conducted a closed reactor study using soil and water containing the constituents of concern.
The site soils initially were evaluated for oxidant demand. Treatment was performed by blending
125 grams of site soil, 140 ml distilI -,d water, and appropriate concentrations of each chemical
oxidant. A series of ten batches was performed at various addition rates. For potassium
permanganate, the treatment concentration was varied from 39 to 20,000 mg/L, while persulfate
concentrations ranged from 90 to 46,000 mg/L. A control slurry sample for each series was also
monitored for this phase of testing.
The total oxygen demand in the sample treated with permanganate was determined by evaluating
the color differences. The sample Arith the lowest permanganate concentration, where a notable
pink color could still be determined, was selected for total oxidant demand. The soil portion
from this sample was separated from the water phase by decanting.
Table 23 presents the batch oxidation mixtures developed by Kemron for potassium
permanganate and sodium persulfate. This table includes the oxidant type, the addition rate for
each chemical reagent and mixture monitoring information. The results indicate that relatively
high levels of residual potassium permanganate are present at an addition rate of 2,500 mg/L and
residual sodi�.:m persulfate is present at an addition rate of 5,750 mg/L. The results also indicate
3555/3555_102 Page 21 of28 KEMRONENVRONNT NTA% SERVICES, INC.
APPLIED T ECFENOLOGIES GROUP

Table 23
Preliminary Oxidation Treatment
Treatment Overview
Kennon Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
KEMRON
SAMPLE
No,
UNTREATED
MATERIAL
TYPE
REAGENT
TYPE
ADDDITION
RATE
(mg/L)
INCUBATION
TIME
Days
pH
(s.u.)
ORP
(mV)
Water
Color
3555-001
Ground water
-
0
7 and 28
-
-
3555-002
Ground water
KMn04
5,000
7
3555-003
Ground water
NaS208/Ferrous Sulfate
11,500/12.5
28
-
-
-
3555-004
Soil/dH2O
NaS20g/Ferrous Sulfate
46,000/12.5
14
2.0
266
Blue
3555-005
Soil/dI120
NaS208/Ferrous Sulfate
23,000/12.5
14
2.4
245
Blue
3555-006
Soil/d1I20
NaS20g/Ferrous Sulfate
1 I,500/12.5
14
2.7
222
Blue
3555-007
Soil/dII20
NaS20g/Ferrous Sulfate
5,750/12.5
14
3.1
200
light blue
3555-008
Soil/dH2O
NaS20g/Ferrous Sulfate
2,875/12.5
14
3.6
174
light blue
3555-009
Soil/dII20
NaS208/Ferrous Sulfate
1,437/12.5
14
4.2
140
Clear
3555-01.0
Soil/dH2O
NaS20g/Ferrous Sulfate
710/12.5
14
5.6
71
Clear
3555-011
Soil/dH2O
NaS20g/Ferrous Sulfate
359/12.5
14
6.1
39
Clear
3555-012
Soil/dH20
NaS20g/Ferrous Sulfate
180/12.5
14
6.3
20
Clear
3555-013
Soil/dII20
NaS20g/Ferrous Sulfate
90/12.5
14
6.6
12
Clear
3555-01.4
Soil/dH2O
-
0
14
6.9
-17
Clear
3555-015
Soil/dI-I20
KMnO4
20,000
7
7.3
-20
Dark Purple
3555-016
Soil/d1I20
KMn04
10,000
7
7.3
-24
Dark Purple
3555-017
Soil/dI120
KMn04
5,000
7
7.2
-27
Dark Purple
3555-018
Soil/dH2O
KMn04
2,500
7
7.1
-30
Dark Purple
3555-019
Soil/dH2O
KMn04
1,250
7
7.1
-23
Purple
3555-020
Soil/dH20
KMn04
625
7
7.2
-22
pink
3555-021
Soil/dH2O
KNln04
313
7
7.1
-20
Clear
3555-022
Soil/dII20
KMn04
156
7
7.2
-21
Clear
3555-023
Soil/dH2O
KMn04
78
7
7.2
-20
Clear
3555-024
Soil/d1I20
KMn04
39
7
7.1
-2.1
Clear
3555-025
Soil/dH2O
0
7
7.0
-20
Clear
Applied Technologies Group
3555 213.xls

that the addition of potassium permanganate has little impact on pH or oxidation-reduction
potential (ORP). However, the addition of sodium persulfate can result in substantially lower pH
values and increased ORP values.
As directed by the Client, both potassium permanganate and sodium persulfate in groundwater
spiked with the constituents of concern were evaluated initially at single concentrations of 11,500
mg /L and 2,875 mg/L, respectively. A corresponding control sample for each of the treated
samples was also monitored without oxidant addition. The treated ground water and control
samples were allowed to react at room temperature for seven days for potassium permanganate
and twenty-eight days for persulfate, respectively. During this incubation period all samples
were agitated daily. Upon reaching the specified incubation period, each sample was preserved
with concentrated HCI, cooled to 4° C and submitted to CompuChem for VOC analyses. The
results of the VOC analyses for the addition of sodium persulfate are summarized in Table 24.
The soil portions of the mixtures were cooled to OC and submitted for analytical testing to
evaluate potential manganese leachability from these samples, as determined by the SPLP
method. The results of these tests are summarized in Table 24.
Kemron also evaluated sodium permanganate as an oxidizing agent in samples containing spiked
groundwater and soil/ groundwater, respectively. The oxidizer was added at two addition rates of
1,250 and 2,500 mg/L, as summarized in Table 25 and Table 26. The samples were incubated
for 14 days at 15 'C. Residual oxidant was present in the soil/ groundwater sample at a sodium
permanganate concentration of 2,500 mg/L. At the conclusion of the incubation period, samples
were shipped to CompuChem for VOC and metal analyses, as summarized in Table 26 and
Table 27.
Ken -iron conducted a treatability oxidation study with hydrogen peroxide in a closed reactor. The
treatability study was conducted on a 400 ml 1:1 slurry of untreated soil and groundwater from
the site. The reactor used was a 500 ml three port glass container. One port was connected to a
tube connected to a Summa canister in which the off gas was collected. A flow meter set for 2
hours was fitted to the Summa canister to control the rate at which the off gas was collected. A
thermometer was fitted in the second port. In the third port, a funnel for the addition of the
hydrogen peroxide reagent was fitted. The reactor was placed on a shaker table running at 150
rpm.
To evaluate treatability employing hydrogen peroxide, three addition rates were evaluated. The
rates were 20 mL H2O2/L slurry, 40 mL H2O2/L slurry, and 80 mL H20?/L slurry, respectively. A
control sample with no addition of hydrogen peroxide also was tested. The hydrogen peroxide
solution used was a 5% solution in which the nH -was adjusted to 5 usinE, 1 H2SO4. As a
3555i3555_102 Pan 22of28 KEv-L.JEP", F ,LAC.
_kPP?..t`D TEC_LNOLOGES GROUP

Table 24
Preliminary Oxidation Treatment
Treatment Overview
Kemron Environmental Services, Inc.
Duracell - Lexington Site Trealabilly Study
KEMRON
UNTREATED
ADDDITION
INCUBATION
SAMPLE
I
MATERIAL
j
RL'AGENT
RATE
TIME
PARAMETER
1tLSUl_'T
No.
'TYPE
TYPE
m /L
Days
TCLP VOAs u /I
3555-00I-28
Ground water
0
28
1, 1 -Dichloroethene
520
(CRQL=IOU ppb)
1,1,2-Trichloro-1,2,2-triflouroetlhane
41 J
Methylene Chloride
260
trans-1,2-Dichloroethene
99 J
1,1-Dichloroethane
330
cis-1,2-Dichloroethene
590
Chloroform
17 J
1, 1, 1 -Trichloroethane
2300 1)
Carbon Tetrachloride
590
1,2-Dichloroethane
230
Trichloroethene
1800
Tetrachloroethene
1500
L'thylbenzene
9 J
Xylene (total)
30 J
3555-003
Ground water
NaS2O8/Ferrous Sulfate
I1,500/12.5
28
1,1-Dichloroethene
40 J
(CRQL. 250ppb)
1,1,2-Trichloro-1,2,2-lriflouioethane
170 J
Acetone
190 1
Methylene Chloride
250
1,l-Dichloroethane
350
1,1,1-1'richloroethane
3600
Carbon Tetrachloride
320
1,2-Dichloroethane
200 J
SPLP Metals u I
3555-008
Soil/d112O
NaS2O8/Ferrous Sulfate
2,875/12.5
14
Mn
856
3555-014
Soil/dH2O
-
0
7
Mn
69.2
3555-020
Soil/dH2O
KMnO4
625
7
Mn
6.6 B
3555-025
Soil/dII2O
0
7
Mn
14.9 B
1 CRQL - Contract Required Quantilation Limit. Instrument Detection Limit (IDL) is apporximately 10-20 time less than the CRQL.
Analytical Result Oualifiers
J - reported value less than the CRQL but greater than or equal to the IDL
D - analyze was diluted and reanalyzed
11 - reported value less than the Contract Required Detection Limit (CRDL) but greater than or equal to the IDL
3555 228.xls
Kemron Environmental Services, Inc
Applied Technologies Group

Table 25
Oxidation Treatment
Treatment Overview
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
KEM RON
SAMPLE
No.
UNTREATED
MATERIAL
TYPE
REAGENT
TYPE
ADDITION
RATE
(mg/L)
INCUBATION
TIME
Days
INCUBATION
TEMPERATURE
oC
pH
(s.u.)
ORP
(mV)
Water
Color
3555-026
Spiked Ground water
-
0
14
15
-
-
3555-027
Spiked Ground water
NaMn04
1,250
14
15
-
-
-
3555-028
Spikcd Ground water
NaMn04
2,500
14
15
-
-
-
3555-029
Soil/dl-]:20
_
0
14
15
7.4
-23
-
3555-030
Soil/dII20
NaMn04
1,250
14
15
7.2
-20
light reddish
3555-031
Soil/d1-120
NaMn04
2,500
14
15
7.3
-26
dark purple
d1120: demincralized water
Applied Technologies Group
3555 219.x1s

Table 26
Preliminary Oxidation Treatment
Treatment Overview
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
KFAI RON
UI FIREATED
ADDDITION
INCUBATION
SAMPLE
MATERIAL
REAGENT
RATE
TIME
PARAMETER
RESULT
No.
TYPE
TYPE
(m )
Days
TCLP YOAs (u /1)
3555.026
Spiked ground water
-
0
14
1, 1, 1 -Trichloroethane
1500 D
(CRQL=10ppb,
1, 1,2-Trichloro- 1,2,2-triflouro ethan e
150
for those flagged D
1,1,2-Trichloroethaue
4 J
CRQL=100 ppb)
1,1-Dichloroethane
260 D
1, 1 -Dichloroethene
490 D
1,2-Dichloroethane
150
Benzene
3 J
Carbon Tetrachloride
460 D
Chloroeihane
6 J
Chloroform
12
cis-1,2-Dichloroethene
520 D
Cyclohexane
2 J
Methylcyclobexane
1 J
Methylene Chloride
120
Tetrachloroethene
1100 D
trans-1,2-Dichloroethene
71
Trichloroethene
1600 D
Vinyl Chloride
9 J
3555-027
Spiked ground water
NaNlnO,
1,250
14
1,1,l-Trichloroethane
1700
(CRQL=100 ppb)
1,1,2-Trichloro-1,2,2-triflouroethane
48 J
1,1-Dichloroethene
340
1,2-Dichloroethene
170
Carbon Tetrachloride
490
Chloroform
13 J
Methylene Chloride
140
prxea grouna water
(CRQL=100 ppb)
1,1,2-Trichloro-1,2,2-triflouroethane
150
1,1-Dichloroethane
300
1,2-Dichloroethene
150
Carbon Tetrachloride
550
Chloroform
13 J
Methylene Chloride
140
' CRQL --Contract Required Quantitation Limit Instrument Detection Limit (IDL) is apporximately 10-20 time less than the CRQL
Analvtical Result Oualifiers
J - reported value less than the CRQL but greater than or equal to the IDL
D - analyze was diluted and reanalyzed
B - reported value less than the Contract Required Detection Limit (CRDL) but greater, than or equal to the IDL
NT - sample spike recovery outside of control limits.
Pemron Ear°ironmental Services, Inc.
Applied Technologies Group
3555 236.-xis

Table 27
Oxidation Study
Analytical results
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
KEMRON
SAMPLE
UNTREATED
MATERLAL
REAGENT
REAGENT
ADDITION
METALS ANALYSES
Manganese
Mercury
No.
TYPE
TYPE
(mg/L)
(ug/L)
I (ug/L)
3555-029
SoiUdH20
-
0
231
1.5
3555-030
SoiUdH20
NaMn04
1.250
3.7
32.2
3555-031
SoiUdH20
NaMn04
-17500
17.3
46.5
dH20: Demineralized Water
Kezron Enx:ro=ental Senices, Inc.
3555 231-:tits _Applied Technologies Group

catalyst for the reaction, 100 mg/L Fee+ (as FeSO4) was added. Since the iron plus peroxide
Fenton's solution was very unstable, it was prepared immediately before addition to the reactors.
The Fenton's reagent was added at a rate of approximate 5 mL/minute. The pH in the slurries
was measured before addition of the Fenton's reagent and at the conclusion of the reaction
period. The temperature in the reactors was monitored closely over the 2-hour reaction period.
The data are summarized in Tables 28 throuah 31 for each of the four reactors. After the 2 hours
of reaction time, a fraction of the slurry from each test was filtered and tested for residual
peroxide by adding KI/starch indicator and H2SO4. The peroxide screening tests indicated that
the free water contained residual hydrogen peroxide at the conclusion of the 2 hour reaction
period. The color of the sample with addition rate of 20 mL H2O2/L slurry had a slightly blue
color after addition of the indicator. For the two samples with higher addition rates of H2O2 the
color was very dark blue. The control sample was clear in color when tested for H2O2. The
Summa canisters in which the off gases were collected for the control sample and the sample
with an addition rate of 40 mL H2O2/L slurry were sent to the Severn Trent Laboratories for
analyses. In addition, the soil and water phases from these two samples were sent to
CompuChem for VOC analysis. Table 32 summarizes the results of these air, soil and water
samples.
4.4 CHEMICAL OXIDATION SCREENING RESULTS
A review of Table 24 reveals that the spiked concentrations of VOCs, with exceptions of 1,1-
dichloroethene, methyl chloride and 1,1,1-trichloroethane, had decreased in the sample oxidized
with sodium persulfate in contrast to the control sample after the 28-day reaction period. The
concentrations of spiked carbon tetrachloride and 1,2-dichloroethane had decreased only slightly,
Acetone was not present in the spiked sample but was present in the final sample. A review of
Table 26 reveals that the spiked concentrations of VOCs had increased or remained the same in
the samples oxidized with sodium permanganate in contrast to the control sample after the 14
day reaction period. The increased concentrations for some compounds may be due to variability
in the laboratory analyses of VOCs and/or as degradation products. The elimination or
significant reduction of chlorinated ethees, but not chlorinated ethanes or methanes, is
consistent with the behavior of unheated sodium persulfate.
The SPLP leachate results for manganese in Table 24 reveal an increased manganese
concentration in the sample with sodium persulfide when compared to the control sample. For
the sample treated with potassium permanganate, however, a decrease in the manganese
concentration is observed when comparing the treated sample with the control sample. The
treated sample had a manganese concentration of 6,6 ug L and the untreated had 1419 ug/L of
3555/3555_102 Pa-e 23 of 28 IiEviRON FN'ti,jRo, ?r 1AL SER-ICES, h,C.
PPT 7i D TEC_FNOLOGES GROUT

Table 28
Oxidation Treatment
Treatment Overview
Kemron Environmental Services, Inc
Duracell - Lexington Site Treatability Study
Date Collected:
3/ 14/2002
Vol. of H2Oz :
0 ml
rpm
150
Sample ID:
9346-B
Vol. of Slurry:
400 ml
Sampling time:
2 hrs
Kemron ID:
071
pH initial:
6.29
Initial vacuum:
-30 inHg
Project #
3555
pH final:
7.05
Final vacuum:
-8 inHg
Time
(minutes)
Temperature
reactor (°C)
Temperature
room (°C)
0
22.9
22.5
10
22.9
22.7
20
22.9
-
30
22.9
22.6
40
23.0
-
50
23.2
22.6
60
23.2
-
70
23.1
22.9
80
23.1
-
90
23.0
23.0
100
23.2
-
110
23.5
23.1
120
23.5
23.1
- Not measured
Kemron Environmental Sel771ces, Inc.
N L'.xis Applied Technology es Group

Table 29
Oxidation Treatment
Treatment Overview
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
Date Collected:
3/14,2002
Vol. ofR02:
8 nil
rpm
150
Sample ID:
12585
Vol. of Sluny:
400 ml
Sampling time:
2 hrs
Kemron ID:
072
pH initial:
6.06
Initial vacuum:
-30 inHg
Project #
3555
pH final:
6.69
Final vacuum:
0 inHg
Time
(minutes)
Temperature
reactor (°C)
Temperature
room CC)
0
21.3
21.4
10
21.6
-
20
22.2
-
30
22.5
-
40
22.7
-
50
22.9
22.7
60
23.0
-
70
23.1
22.8
80
23.2
22.6
90
23.2
22.5
100
23.3
22.4
110
23.3
-
120
23.3
22.4
- Notmeasured
Kemron Environmental Senaces, Inc.
55 072 Applied Tecbnolc-ie, Group

Table 30
Oxidation Treatment
Treatment Overview
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
Date Collected:
3/15/2002
Vol. ofHO, :
16 ml
rpm
150
Sample ID:
12592
Vol. of Slurry:
400 ml
Sampling time:
2 hrs
Kemron ID:
073
pH initial:
6.18
Initial vacuum:
-30 inHg
Project #
3555
pH final:
6.61
Final vacuum
-10 inHg
Time
(minutes)
Temperature
reactor CC)
Temperature
room ('Q
0
20.9
21.0
10
21.1
21.1
20
21.2
21.0
30
21.3
21.1
40
21.5
21.1
50
21.6
20.9
60
21.7
21.1
70
21.8
21.2
80
21.8
21.1
90
21.9
21.2
100
21.9
21.3
110
22.0
21.3
120
22.1
21.5
- Not measured
3555 073
Kemron Environmental Sen-ices, Inc.
Applied T--hnologies Group

Table 31
Oxidation Treatment
Treatment Overview
Kemron Environmental Services, Inc.
Duracell - Lexinb on Site Treatability Study
Date Collected:
3/15/2002
Vol. of H202 :
32 ml
rpm
150
Sample ID:
03322
Vol. of Slurry:
400 ml
Sampling time:
2 hrs
Kemron ID:
074
pH initial :
6.02
Initial Vacuum:
-30 inHg
Project #
3555
pH final:
6.69
Final vacuum:
-10 inHg
Time
(minutes)
Temperature
reactor (°C)
Temperature
room (°C)
0
22.6
22.7
10
22.9
22.9
20
22.4
23.1
30
22.9
23.2
40
23.3
23.3
50
23.6
23.1
60
23.8
23.3
70
24.1
23.1
80
24.2
23.3
90
24.2
23.2
100
24.3
23.2
110
24.4
23.3
120
24.5
23.4
- Not measured
Kemron En--iro=ental Services, Inc.
Applied Technolczes Group

manganese, indicating less soluble manganese is present after oxidation. Based on the test
results, mobilization of manganese does not appear to be a problem associated with the
introduction of the oxidants tested.
Manganese and mercury analyses for the water phase of the samples treated with sodium
permanganate in combinations of soil and de -mineralized water are summarized in Table 27.
The results reveal that manganese concentrations decreased from 231ug/L in the untreated
sample to 3.7 and 17.3 ug/L, respectively, in samples treated with 1,250 and 2,500 mg/L
oxidizer. This may suggest that manganese is being oxidized to a less soluble form. For
mercury, an increase in concentration is detected in the treated samples compared to the
untreated sample in which the mercury concentration is only 1.5ug/L. The treated samples had
mercury concentrations of 32.2 and 46.5 ug/L in the samples oxidized with 1,250 and 2,500
mg/L sodium permanganate, respectively. This suggests that the mobility of mercury maybe
increased due to the addition of certain oxidants. However, the duration of the increased
mobility or the long-term behavior of mercury once oxidizing conditions are dissipated can not
be determined based on this testing.
A review of the results in Table 28 through 31 indicates that the temperature in the reactor
stabilized within the 2-hour timeframe for all three addition rates tested. This indicates that 2
hours is sufficient reaction time for the oxidation process to occur. The increase in temperature
of the test reactors ranged between 1 °C and 2°C, while the temperature in the control reactor
increased 0.6°C. When testing for residual hydrogen peroxide at the conclusion of the 2-hour
reaction period by adding KI/ starch indicator and H2SO4, only a slightly purple color was
detected in the reactor with an addition rate of 20 mL H2O2/L slurry. For the two remaining
reactors, with addition rates of 40 mL H2O2/L slurry and 80 mL H2O2/L slurry, the colors after
addition of the indicator were very dark blue indicating the presence of high residuals of
hydrogen peroxide.
A comparison of the results of the VOCs collected in the Summa canisters in the treated and the
untreated sample (Table 32) indicates that most of the VOC concentrations did not decrease
significantly due to addition of hydrogen peroxide. For most compounds, an increase in
concentration was measured. Specifically, this increase was observed in the reported air
concentrations for 1, 1 -dichloro ethane, 1,1-dichloroethene, 1, 1,2-trichloro- 1,2,2-triflouro ethane,
methyl chloride, 1,1,1-trichloroethane, trichloroethene, and vinyl chloride. This indicates that the
VOCs were being volatilized instead of oxidized. Also an oxidation of the natural occurring
organics will take place, however it is presumed that this does not reduce the oxidation of the
VOCs since there is a high level of residual peroxide present after the 2 hours of testing. Often,
these naturally occi?ning ora nic materials in soils are oxidized prior to other contaminants. The
355513555_102 Page 24 of 28 KEIvIRON EN\TtONIVIENT_ L SER' 7=S, NC.
t�npr IED TECI�OTOGI~S GROUP

Table 32
Preliminary Testing SurJmllary
Peroxide Treatment
Kemron Environmental Services, Inc.
Dnracell -.Lexington Site Treatability Study
7'>-?S'f1NG
_ ARM A.G+TPi�
P
VOLATILES ( b)
3555-071
VOLAIILES (ppb)
3555-073
Acelone
Air ug 1113)
<240
So>1(ug/kg)
Liquid ug L)
Aar (ug m3
Sort u , kg
Liquid ug L
l3cn.zellc
<49
860
<330
2.
15
13roniodichloroinethane
<49
14
<10
<66
0.8
7
l3ronJolor17)
<49
<14
<14
<
<66
<14
<10
131-017ome(hane
<49
<14
<10
10
<66
<14
<10
Cal -bon disulfide
<240
<14
1
<66
<14
< 0
1
Carbon. tetrachloride
<49
<14
< 10
<330
<14
<10
Chlorobenzene
<49
<10
<66
<1.4
< 10
Cbk)rocthanc
<97
<
<14
14
<10
<66
<14
<10
C111U1'oforril
<10
<130
<14
<10
Chlo.romethatic
597
<
<15
0.9
1,2-DJbJ'OrnOCCllilnC
<49
<14
0.6<14
0.6
3
<130
0.5
0.9
DibJ:oJJJocldoromcll7aJJe
<14
<10
<66
<14
<10<49
1,2-D1chlOrobell Zell e
<49
<14
<10
<66
<14
<10
1.,3-.Dichlorobeuzeiic
<49
<14
<10
<66
<14
<10
1,4-.Diclil.orobell Zell e
<49
<14
<10
<66
<14
<10
1_)iclilorodiflu01:0111ctllalJe
<49
<14
<10
<66
<14
<10
1,1.-Dichloroethane
1.,200
<14
<14
<10
<66
<14
<10
1,2-Dichlorocthane
<49
<10
1,600
7
7
1,'1-Dichloroethene
4,200
<14
<14
<10
<66
<14
<10
cis-J.,2-Dichloroethcilc
3,5 00
<14
<10
8,600
7
7
I ra n s-1, 2-Di chloro c tt7 elie
<49
<14
<10
3,500
22
25
1,2-Dichloropropane
<49
<10
<66
<14
<10
cis-1,3-Dichloropropclle
<49
<14
<10
<66
<14
<10
trans-l.,3-1)i.chloropropene
<49
<14
<14
<10
<66
<14
<10
1,2-Dichloro-1,1,2,2-teiraflouroetllane
<49
<10
<66
<14
<10
1, 1,2'1.'richloro-1,2,2-trillouroethazle
910
<14
<66
Ltbylbenzene—
<49
<14
<10
<10
1,700
10
2
<66
<14
<10
3555_237.xls Page 1 of 2 Kemron. Environmental Services, Inc

Table 32
Preliminary Testing Summary
Peroxide Treatment
Kemron Environmental Services, Inc.
Duracell - Lexington Site Treatability Study
'1'ESUNG
VOLATILES (p b)
VOLATILES pU
3555-071
3555-073
PARAMETER
Air ug rn3
Soil u kg
Liquid ug L
Air (ug m3)
Soil a kg
Lr uid ug L
4-ethyl Toluene
NM
<66
I. J.exa.chlorobutadiene
<97
<130
241exanon.e
<240
<14
<10
<330
<14
<10
Methyl ethyl ketone (MEK)
<240
<330
4-Methyl-2-penlanone (M1BK)
<240
<14
<10
<330
<14
<10
Methylene chloride
71
0.8
<10
75
2
0.8
Styrene
<49
<14
<10
<66
<14
<10
1,1.,2,2-,retrachloroetliaue
<49
<14
<10
<66
<14
<10
'1'elrachloroethen.e
140
2
<10
130
7
0.9
Toli.rerre
<49
0.7
<10
<66
<14
2
1.,2,4 `1'richlorobenzene
<120
<14
<10
<t70
<14
<10
1,1., J.-Tri.chl.orocthaae
4,900
0.7
<10
7,700
31
14
1,1,2-Triell l.oroethane
<49
<14
<10
<66
<14
0.6
Trichloroelhcnc
4,800
0.8
<10
5,800
56
27
I'ri ell lorolluoromethan.e
<49
<14
<10
<66
<14
<10
1,2,4 Trimethylbenzene
<49
<66
1,3,5- I'rjmeth.ylbenzene
<49
<66
Vinyl Acetate
<240
<330
Vinyl Chloride
96
<1.4
<10
240
<14
<1.0
Xy.leues (total)
<49
<14
<10
<66
<14
<10
NR : Not Measured
3555 237.xls Page 2 of 2 Kemron Environmental Services, Inc

difference in increased temperature in'the reactors for the two samples is not significant enough
to draw any conclusion; however, the difference in temperature may have contributed to the
higher VOC concentrations in air from the treated sample, in which the temperature increased 1.2
°C, compared to the untreated, in which a temperature increase of 0.6°C was detected. Note,
however, that the final temperature in the treated sample was 1.4°C lower than for the untreated.
For the soil data presented in Table 32 there is a somewhat higher amount of detected VOCs in
the liquid phase of the treated sample than in the control sample. Review of the data reveals that
many of these results are reported as below the quantitation limit of 10 ug/L, indicating that these
are most likely non -detected or estimated values. For the soil phase only a few values in the
treated samples are above the quantitation limit of 14 ug/Kg. These values may be due to the soil
samples not being completely homogeneous. The values of detected VOCs below 14 ug/kg may
be estimated or non -detected, and the-efore are difficult to compare. Note that Kemron has not
reviewed the actual analytical data reports.
3555/3555_102 Page 25 of 28 KFMRON SERVICES, LNC.
APPLLD TECPTIOILOGIES GROUT

5.0 CONCLUSIONS / RECOAUVIENDATIONS
Kemron has performed the Duracell site treatability study to screen a variety of technologies
identified as potentially capable of remediating the site. Specifically, the treatability study has
been performed to 1) determine the untreated characteristics of soils and ground water sampled
from the site, 2) perform bench -scale testing to evaluate potential remedial technologies, and 3)
perform comprehensive bench -scale treatment evaluations of various soil/reagent combinations
to assess effectiveness and optimize reagent ratios.
For the treatability testing the results strongly indicate that treatment with mixtures of
cement/lime/sodium sulfide at the rate of 10/5/2.5 % or 10/5/1.25 °io improve the material
characteristics. Substantial consistent differences in performance were not observed between
these two reagent blends. Besides improving the physical strength of the samples these mixture
designs also decrease leachable mercury to values below the treatment criterion of 11 ug/L for
most of the tested samples. Note that some variability has been observed which is attributed to
heterogeneity in the samples.
ERM and Duracell observed that the multiple extraction testing designed to assess the long-term
performance of selected reagent blends, as measured by leachability of mercury, indicated two
significant findings. First, there was no increase in the rate of mercury leaching in the stabilized
material subjected to repeated leaching. Second, the rate of leaching actually decreased in the
stabilized material that had been crushed relative to the rate in the bulk stabilized material.
These findings suggest that the leachability of mercury in the stabilized material will not increase
over time and will not increase if the stabilized material is broken into smaller pieces over time.
Furthermore, it was observed that the average concentration of leachate from both composite
sample types was below the leachate concentration calculated to achieve the 1.1 ug/L ground
water performance goal at the property boundary.
Based on the results of the stabilization/solidification treatability study, it is concluded that either
reagent mixture (e.g., cement/lime/sodium sulfide at the rate of 101512.5 % or 101511.25 %)
would be appropriate for use in stabilizing soils containing mercury and manganese at the
Duracell Lexington Site.
The results of the chemical oxidation treatability study demonstrated that both permanganate and
persulfate were effective reagents in degrading chlorinated ethenes, but were less effective in
degrading chlorinated ethanes and methanes. These results are generally consistent with results
observed in previous treatability assessments using these two oxidants.
5»i �»_102 Page 26 of 28 IiE.viR023 E�-IitO�ivlE?�TAL StR� IC�S, LAC.
_opT rTE i TECIzTOLOGIES GROUP

Treatability testing indicated that Fenton's Reagent was able to treat all three classes of VOCs.
However, some of the VOCs were volatilized during treatment. Also, there were some residual
VOCs remaining in the soil after treatment with Fenton's Reagent.
Because four of the five most abundant VOCs at the Site are chlorinated ethenes (PCE, TCE,
1,2-DCE and 1,1-DCE), the focus of treatment should be on the chlorinated ethenes. TCA, the
second most abundant VOC, has a much higher MCL and RG than do the four chlorinated
ethenes and, therefore, is of secondary significance.
To insure the treatment of VOC COC, especially the chlorinated ethenes, it is recommended that
a two -stage oxidation treatment be employed. In the first stage, a mixture of hydrogen peroxide,
sodium persulfate, and an iron R catalyst will be used. In the second stage, if needed, sodium
permanganate will be used. The two -stage process would allow initial treatment of the three
classes of VOC with a follow-up treatment designed to specifically treat residual chlorinated
ethenes.
3555i3555 102 Paae 27 of 28 FiEMROND�`]RONNMNT.AL SERVICES, NC.
_4PP= T=CHNOLOGIEs GROLP

6.0 QUALITY ASSURANCE/QU_ALITY CONTROL
Kemron maintains strict Quality Assurance (QA) and Quality Control (QC) programs as part of
Kemron's standard operating procedures. The QA/QC program for the Duracell site bench -scale
stabilization study had two primary objectives: 1) to validate the quality of each analysis
conducted in accordance with the referenced protocols, and 2) to evaluate the effectiveness of
each treatment process on the various site soils that were evaluated. These objectives were
achieved for the treatability testing through 1) calibration of the associated equipment, and 2)
supervision and review by qualified technical personnel.
All analytical testing for this project has been performed by CompuChem under the direction of
the Client. As such, Kemron can make no conclusions as to the QA/QC methodologies or results
for this project. However, ERM has indicated that all analytical testing conducted by
CompuChem have been conducted using approved EPA methodology. Furthermore, all reports
issued by CompuChem contain full QA/QC documentation.
35 5 5/355 _102 Page 28 of 28 K:-wiRON _AL SERVICES, INC.
APPLIED `I ECHtiOLOGLES GROLP

Attachment C
MSDS and Carus Fact Sheet
for Sodium Permanganate

LIQUOX6
Sodium Permanganate
CAS No. 10101-50-5
LIQUOX° sodium permanganate is a liquid oxidant recommended for applications that require a concentrated permanganate
solution.
Product Specifications Shipping Containers
Assay
40% minimum as NaMn04
5 gallon (18.9L) Tight Head HDPE jerrican
Insolubles
< 0.005%
(UN Specification: 31-11) made of High Density Polyethylene
pH
6.0 - 8.0
(HDPE), weighs 3.5 lb (1.6 kg). The net weight is 57 lb
Specific Gravity
1.36 - 1.39
(25.7 kg). The jerrican stands approximately 15.33 in. tall,
Solubility in Water
Miscible with water in all
10.2 in. wide and 11.4 in. long (38.94 cm tall, 25.91 cm wide,
proportions.
28.96 cm long).
5 gallon 118.9L1 Tight Head Steel Drum
(UN Specification: 1A1) made of 12 gauge, mild steel,
Chemical/Physical
Data
weighs 5 lb (2.3 kg). The net weight is 57 lb (25.7 kg). The
drum stands approximately 13.75 in, tall and is 11.5 in. in
diameter. (34.93 cm tall, 29.21 cm diameter)
Formula
NaMnO,
Appearance
Dark Purple Solution
55 gallon (208.2L1 Closed Head Steel Drum
Potassium
1000 - 2200 ppm
(UN Specification: 1A1) made of 16 gauge, mild steel,
Stability
> 18 Months
weighs 53.7 lb (24.4 kg). The net weight is 550 lb (249.5 kg).
The drum stands approximately 34.6 in. tall, has an outside
diameter of 23.5 in., and an inside diameter of 22.5 in.
(87.88 cm tall, OD 59.69 cm, ID 57.15 cm).
Applications
• Printed Circuit Board Desmearing
• Fine Chemical Synthesis
• Soil & Groundwater Remediation
• Metal Cleaning Formulations
• Acid Mine Drainage
• Hydrogen Sulfide Odor Control
Remote Locations
Unheated Locations
Benefits
- Concentrated liquid oxidant is easily stored and handled.
Feed equipment is simplified (no. need to transfer and
dissolve crystalline product).
• Dust problems associated with handling dry oxidants
are eliminated.
- High solubility at room temperature. Reactions requiring
a concentrated permanganate solution can be conducted
without having to raise the temperature.
- Can be used instead of potassium permanganate
whenever the potassium ion cannot be tolerated, or if
dusting is a critical issue.
Handling and Storage
Like any potent oxidant, LIQUOXasodium permanganate should
be handled with care. Protective equipment during handling
should include face shields and/or goggles, rubber or plastic
gloves, rubber or plastic apron. If clothing becomes spotted,
wash off immediately; spontaneous ignition can occur with
cloth or paper. In cases where significant exposure exists, use
of the appropriate NIOSH-MSHA dust or mist respirator or an
air supplied respirator is advised.
The product should be stored in a cool, dry area in closed
containers. Concrete floors are preferred. Avoid wooden decks.
Spillage should be collected and disposed of properly. Contain
and dilute spillage to approximately 6% with water and reduce
with sodium thiosulfate, a bisulfite, or ferrous salt. The bisulfite
or ferrous salt may require dilute sulfuric acid to promote
reduction. Neutralize any acid used with sodium bicarbonate.
Deposit sludge in an approved landfill or, where permitted,
drain into sewer with large quantities of water.
As an oxidant, the product itself is non-combustible, but will
accelerate the burning of combustible materials. Therefore,
contact with all combustible materials and/or chemicals must
be avoided. These include, but are not limited to: wood, cloth,
organic chemicals, and charcoal. Avoid contact with acids,
peroxides, sulfites, oxalates, and all other oxidizable inorganic
chemicals. With hydrochloric acid, chlorine is liberated.

Shipping
IQUOX° sodium permanganate is classified as an oxidizer.
odium permanganate is shipped domestically as Class 70 and
pas a Harmonized Code for export of 2841.69.0000.
Proper Shipping Name: Permanganates, Inorganic, Aqueous
solution, n.o.s. (Contains Sodium
Permanganate)
Hazard Class: 5.1
Identification Number: UN 3214
Packaging Group: II
Label Requirements: Oxidizer, 5.1
Special Provisions: T8-Intermodal transportation in
IM 101 portable tanks
Packaging Requirement: 49 CFR Parts 171 to 180 Sections:
173.152, 173.202, 173.242
Quantity Limitations: 1 liter net for passenger aircraft or
railcar. 5 liters net for cargo aircraft.
Vessel Stowage: D-material must be stowed "ondeck"
on a cargo vessel, but is prohibited
on a passenger vessel. Other
provisions, stow "separated from"
ammonium compounds, hydrogen
peroxide, peroxides and
superperoxides, cyanide compounds,
and powdered metal.
Carus Value Addec'
LABORATORY SUPPORT
Repackaging
When LIQUOXO sodium permanganate is repackaged, the
packaging, markings, labels, and shipping conditions must meet
applicable federal regulations. See Code of Federal
Regulations-49, Transportation, parts 171-180, and the Federal
Hazardous Materials Transportation Act (HMTA).
Corrosive Properties
LIQUOX6 sodium permanganate is compatible with many metals
and synthetic materials. Natural rubbers and fibers are often
incompatible. Solution pH and temperature are also important
factors. The material selected for use with sodium permanganate
must also be compatible with any acid or alkali being used.
In neutral and alkaline solutions, sodium permanganate is not
corrosive to carbon steel and 316 stainless steel. However,
chloride corrosion of metals may be accelerated when an oxidant
such as sodium permanganate is present in solution. Plastics
such as teflon, polypropylene, HDPE and EDPM are also compatible
with sodium permanganate.
Aluminum, zinc, copper, lead, and alloys containing these metals
may be slightly affected by sodium permanganate solutions.
Actual corrosion or compatibility studies should be made under
the conditions in which the permanganate will be used prior to
use.
Carus Chemical Company has technical assistance available to its potential and current customers to answer questions or perform
laboratory and field testing including:
*Feasibility Studies * Toxicity Evaluations *TreatabilityStudies *Analytical Services *Field Trials
CARUS CHEMICAL COMPANY
During its more than 80-year history, Carus' ongoing reliance on research and development, as well as its emphasis on technical support
and customer service, have enabled the company to become the world leader in permanganate, manganese, oxidation, and catalyst
technologies.
G
C A R U S
,
RIM
QIISjbiE CA rel
flood diemfs:r} m? wa&
Carus Chemical Company
315 "Fifth Street
P. O. Box 599
Peru, IL 61354
Tel.[phone]
Fax [phone]
Web: www.caruschem.com
E-Mail: salesmktCcaruschem.com
The information contained is accurate to the best of our knowledge. However, data, safety standards and government regulations are subject to change; and the conditions
handling, use or misuse of the product are beyond our control. Carus Chemical Company makes no warranty, either express or implied, including any warranties of
rchantability and fitness for a particular purpose. Carus also disclaims all liability for reliance on the completeness or confirming accuracy of any information included herein.
_ers should satisfy themselves that they are aware of all current data relevant to their particular uses.
Form #LX1501 copyright' 2000
LIQUOXO is trademark of Carus Corporation. Responsible Care' is a service mark of the Chemical Manufacturers Association.

Page I of 6
Material Safety Data Sheet
Sodium permanganate monohydrate, 97+0/o
ACC# 73234
Section 1 - Chemical Product and Company Identification
MSDS Name: Sodium permanganate monohydrate, 97+%
Catalog Numbers: AC209630050, AC209630500, AC209632500
Synonyms: Permanganic acid, sodium salt; Sodium permanganate
Company Identification:
Acros Organics N.V.
One Reagent Lane
Fair Lawn, N] 07410
For information in North America, call: 800-ACROS-01
For emergencies in the US, call CHEMTREC: 800-424-9300
Section 2 - Composition, Information on Ingredients
CAS#
Chemical Name
Percent
EINECS/ELINCS
10101-50-5
ISodium permanganate
97+
233-251-1
Hazard Symbols: O
Risk Phrases: 8
Section 3 - Hazards Identification
EMERGENCY OVERVIEW
Appearance: green crystalline powder. Oxidizer. Danger! May cause severe eye, skin and
respiratory tract irritation with possible burns. Contact with other material may cause fire.
Target Organs: Blood, kidneys, lungs, nerves.
Potential Health Effects
Eye: May cause conjunctivitis. May cause eye irritation and possible burns. May cause permanent
corneal opacification.
Skin: May cause severe irritation and possible burns.
Ingestion: May cause burns to the gastrointestinal tract. May cause nausea, vomiting, and
diarrhea, possibly with blood.
Inhalation: Inhalation may be fatal as a result of spasm, inflammation, edema of the larynx and
bronchi, chemical pneumonitis and pulmonary edema. May cause burning sensation, coughing,
wheezing, laryngitis, shortness of breath, headache, nausea, and vomiting. May cause acute
pulmonary edema, asphyxia, chemical pneumonitis, and upper airway obstruction caused by
edema.
Chronic: Chronic manganese toxicity through inhalation may result in "manganim", which is a
disease of the central nervous system involving psychic and neurological disorders. Men exposed
manganese dusts showed a decrease in fertility. Chroni c manganese poisoning shows early
symptoms of languor, sleepiness and weakness in the legs. A stolid mask -like appearance of the
face, emo tional disturbances such as uncontrollable laughter and a spastic gait with tendency to
fall in walking are findings in more advanced cases. High incidence of pneumonia has been found
to
in
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Page 2of6
workers exposed to the dust or fume of some manganese compounds.
Section 4 - First Aid Measures
Eyes: Immediately flush eyes with plenty of water for at least 15 minutes, occasionally lifting the
upper and lower eyelids. Get medical aid immediately.
Skin: Get medical aid immediately. Immediately flush skin with plenty of soap and water for at
least 15 minutes while removing contaminated clothing and shoes.
Ingestion: Get medical aid immediately. Do NOT induce vomiting. If conscious and alert, rinse
mouth and drink 2-4 cupfuls of milk or water.
Inhalation: Get medical aid immediately. Do not use mouth-to-mouth resuscitation if victim
ingested or inhaled the substance; induce artificial respiration with the aid of a pocket mask
equipped with a one-way valve or other proper respiratory medical device.
Notes to Physician: Treat symptomatically and supportively.
Section 5 - Fire Fighting Measures
General Information: As in any fire, wear a self-contained breathing apparatus in pressure -
demand, MSHA/NIOSH (approved or equivalent), and full protective gear. Strong oxidizer. Contact
with combustible materials may cause a fire. During a fire, irritating and highly toxic gases may be
generated by thermal decomposition or combustion. Use water spray to keep fire -exposed
containers cool. Use water with caution and in flooding amounts. May accelerate burning if involved
in a fire. Containers may explode when heated. Runoff to sewer may create fire or explosion
hazard.
Extinguishing Media: Use water only! Do NOT use carbon dioxide or dry chemical. Do NOT use
alcohol foams. Contact professional fire-fighters immediately.
Flash Point: Not applicable.
Autoignition Temperature: Not applicable.
Explosion Limits, Lower:Not available.
Upper: Not available.
NFPA Rating: (estimated) Health: 2; Flammability: 1; Instability: 2; Special Hazard: OX
Section 6 - Accidental Release Measures
General Information: Use proper personal protective equipment as indicated in Section 8.
Spills/Leaks: Absorb spill with inert material (e.g. vermiculite, sand or earth), then place in
suitable container. Sweep up or absorb material, then place into a suitable clean, dry, closed
container for disposal. Remove all sources of ignition. Provide ventilation. Keep combustibles
(wood, paper, oil, etc.,) away from spilled material.
Section 7 - Handling and Storage
Handling: Wash thoroughly after handling. Remove contaminated clothing and wash before reuse.
Use with adequate ventilation. Minimize dust generation and accumulation. Do not get in eyes, on
skin, or on clothing. Avoid contact with clothing and other combustible materials. Do not ingest or
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Page 3 of 6
inhale. Use only in a chemical fume hood.
Storage: Keep away from heat, sparks, and flame. Do not store near combustible materials. Keep
containers tightly closed. Store in a cool, dry area away from incompatible substances.
Section 8 - Exposure Controls, Personal Protection
Engineering Controls: Facilities storing or utilizing this material should be equipped with an
eyewash facility and a safety shower. Use adequate general or local exhaust ventilation to keep
airborne concentrations below the permissible exposure limits.
Exposure Limits
Chemical Name
ACGIH
NIOSH
OSHA - Final PELs
Sodium permanganate
inone listed
none listed
none listed
OSHA Vacated PELs: Sodium permanganate: No OSHA Vacated PELs are listed for this chemical.
Personal Protective Equipment
Eyes: Wear appropriate protective eyeglasses or chemical safety goggles as described by OSHA's
eye and face protection regulations in 29 CFR 1910.133 or European Standard EN166.
Skin: Wear appropriate gloves to prevent skin exposure.
Clothing: Wear appropriate clothing to prevent skin exposure.
Respirators: A respiratory protection program that meets OSHA's 29 CFR §1910.134 and ANSI
Z88.2 requirements or European Standard EN 149 must be followed whenever workplace
conditions warrant a respirator's use.
Section 9 - Physical and Chemical Properties
Physical State: Crystalline powder
Appearance: green
Odor: none reported
pH: Not available.
Vapor Pressure: Not available.
Vapor Density: Not available.
Evaporation Rate:Not available.
Viscosity: Not available.
Boiling Point: Not available.
Freezing/Melting Point:dec. before reaching mp
Decomposition Temperature:Not available.
Solubility: Soluble in cold water.
Specific Gravity/Density: Not available.
Molecular Formula: MnNa04.H2O
Molecular Weight:159.94
Section 10 - Stability and Reactivity
Chemical Stability: Stable under normal temperatures and pressures.
Conditions to Avoid: Incompatible materials, ignition sources, dust generation, combustible
materials, reducing agents, strong oxidants.
Incompatibilities with Other Materials: Strong reducing agents, strong acids, acetic acid, acetic
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Page 4 of 6
anhydride, ammonia, finely powdered metals, phosphorus, sulfur, ammonium salts, organic
materials.
Hazardous Decomposition Products: Irritating and toxic fumes and gases, sodium oxide.
Hazardous Polymerization: Has not been reported
Section 11 - Toxicological Information
RTECS#:
CAS# 10101-50-5: SD6650000
LDSO/LC50:
Not available.
Carcinogenicity:
CAS# 10101-50-5: Not listed by ACGIH, IARC, NIOSH, NTP, or OSHA.
Epidemiology: No information available.
Teratogenicity: No information available.
Reproductive Effects: No information available.
Neurotoxicity: No information available.
Mutagenicity: No information available.
Other Studies: No data available.
Section 12 - Ecological Information
Ecotoxicity: No data available. No information available.
Environmental: No data available.
Physical: No data available.
Other: None.
Section 13 - Disposal Considerations
Chemical waste generators must determine whether a discarded chemical is classified as a
hazardous waste. US EPA guidelines for the classification determination are listed in 40 CFR Parts
261.3. Additionally, waste generators must consult state and local hazardous waste regulations to
ensure complete and accurate classification.
RCRA P-Series: None listed.
RCRA U-Series: None listed.
Section 14 - Transport Information
US DOT
IATA
RID/ADR
IMO
Canada TDG
Shipping Name:
pp 9
SODIUM
PERMANGANATE
SODIUM
PERMANGANATE
Hazard Class:
5.1
5.1
UN Number:
UN1503
UN1503
Packing Group:
III
II
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Page 5 of 6
Section 15 - Regulatory Information
US FEDERAL
TSCA
CAS# 10101-50-5 is listed on the TSCA inventory.
Health & Safety Reporting List
None of the chemicals are on the Health & Safety Reporting List.
Chemical Test Rules
None of the chemicals in this product are under a Chemical Test Rule.
Section 12b
None of the chemicals are listed under TSCA Section 12b.
TSCA Significant New Use Rule
None of the chemicals in this material have a SNUR under TSCA.
SARA
Section 302 (RQ)
None of the chemicals in this material have an RQ.
Section 302 (TPQ)
None of the chemicals in this product have a TPQ.
Section 313
This material contains Sodium permanganate (listed as Manganese), 97%,
which is subject to the reporting requirements of Section 313 of SARA Title
(CAS# 10101-50-5)
III and 40 CFR Part
373.
Clean Air Act:
This material does not contain any hazardous air pollutants. This material does not contain any
Class 1 Ozone depletors. This material does not contain any Class 2 Ozone depletors.
Clean Water Act:
None of the chemicals in this product are listed as Hazardous Substances under the CWA. None of
the chemicals in this product are listed as Priority Pollutants under the CWA. None of the chemicals
in this product are listed as Toxic Pollutants under the CWA.
OSHA:
None of the chemicals in this product are considered highly hazardous by OSHA.
STATE
CAS# 10101-50-5 can be found on the following state right to know lists: New Jersey.
California No Significant Risk Level: None of the chemicals in this product are listed.
European/International Regulations
European Labeling in Accordance with EC Directives
Hazard Symbols:
O
Risk Phrases:
R 8 Contact with combustible material may cause
fire.
Safety Phrases:
S 17 Keep away from combustible material.
WGK (Water Danger/Protection)
CAS# 10101-50-5: No information available.
Canada - DSL/NDSL
CAS# 10101-50-5 is listed on Canada's NDSL List.
Canada - WHMIS
This product has a WHMIS classification of C, D2B,
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Page 6 of
Canadian Ingredient Disclosure List
CAS# 10101-50-5 (listed as Manganese) is listed on the Canadian Ingredient Disclosure List.
Exposure Limits
CAS# 10101-50-5: OEL-AUSTRALIA:TWA 5 mg(Mn)/m3 JANUARY 1993 OEL-BE
LGIUM:TWA 5 mg(Mn)/m3 JANUARY 1993 OEL-CZECHOSLOVAKIA:TWA 2 mg(Mn)/m
3;STEL 6 mg(Mn)/m3 JANUARY 1993 OEL-DENMARK:TWA 2.5 mg(Mn)/m3 JANUA
RY 1993 OEL-FINLAND:TWA 2.5 mg(Mn)/m3 JANUARY 1993 OEL-HUNGARY:TWA
0.3 mg(Mn)/m3;STEL 0.6 mg(Mn)/m3 JANUARY 1993 OEL-JAPAN:TWA 0.3 mg(Mn
)/m3 JANUARY 1993 OEL-THE NETHERLANDS:TWA 1 mg(Mn)/m3 JANUARY 1993
OEL-POLAND:TWA 0.3 mg(Mn)/m3 JANUARY 1993 OEL-SWEDEN:TWA -1 mg(Mn)/m
3;STEL 2.5 mg(Mn)/m3 (resp. dust) OEL-SWEDEN:TWA 2.5 mg(Mn)/m3;STEL 5
mg(Mn)/m3 (total dust) OEL-UNITED KINGDOM:TWA 5 mg(Mn)/m3 JANUARY 1
993 OEL IN BULGARIA, COLOMBIA, JORDAN, KOREA check ACGIH TLV OEL IN
NEW ZEALAND, SINGAPORE, VIETNAM check ACGI TLV
Section 16 - Additional Information
MSDS Creation Date: 9/02/1997
Revision #3 Date: 8/02/2000
The information above is believed to be accurate and represents the best information currently available to us. However, we make
no warranty of merchantability or any other warranty, express or implied, with respect to such information, and we assume no
liability resulting from its use. Users should make their own investigations to determine the suitability of the information for their
particular purposes. In no event shall Fisher be liable for any claims, losses, or damages of any third party or for lost profits or any
special, indirect, incidental, consequential or exemplary damages, howsoever arising, even if Fisher has been advised of the
possibility of such damages.
https:/ifscimage.fishersci.conv'msds/ i 3234.htm 2/5/2003

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W A
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Mr. Thomas M. Wilson
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
September 19, 2003
Environmental Resources Management
7300 Carmel Executive Park, Suite 200
Charlotte, NC 28226
Subject: Persulfate Injection at Duracell/Gillette Site
Dear Mr. Wilson:
Alan W. Klimek, P. E. Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
The Underground Injection Control Group of the Groundwater Section of DWQ has reviewed the
information submitted by you on August 11, 2003, regarding the proposed injection of sodium
persulfate and hydrogen peroxide at the Duracell/Gillette site in Lexington, NC. The information
you submitted was also reviewed by Dr. Luanne Williams of the Epidemiology Section of the
Division of Public Health, Department of Health and Human Services. Due to the site's status as a
Superfund site, the state's administrative permitting requirements have been waived for this
project. In light of the lack of a permit requirement, the UIC Program appreciates the opportunity
to review the proposed changes to the original injection plan.
Persulfate injection for groundwater remediation is a relatively new technology for which there
are not many case studies. The chemical processes that will result from the proposed injection of
persulfate, iron EDTA, and hydrogen peroxide are very similar to those that result from injection
of Fenton's reagent, so a similar level of caution is warranted. we strongly urge you to heed the
cautions stated by Dr. Williams in her health risk evaluation of the proposed injectants, dated
September 2, 2003. A copy of this health risk evaluation is enclosed for your reference. It is my
understanding from conversations with you that ERM has reviewed these cautions and feels that
the risk of fire or explosion is only a particular concern when dealing with free product, and that
contaminant concentrations in the proposed injection zone are low enough that ERM does not
perceive this to be a hazard at this site. Nevertheless, I urge you to review and heed Dr.
Williams' cautions and to closely monitor the injection process and hydrogen peroxide
concentrations throughout the project.
NMENOR
N. C. Division of Water Quality / Groundwater Section
1636 Mail Service Center Raleigh, N.C. 27699-1636 Customer Service
Phone: [phone] Fax: [phone] Internet: http://gw.ehnr.state.nc.us 1'877123-G748

Mr. Thomas Wilson
September 19, 2003
Page 2
As stated in our previous review summary, dated April 10, 2003, for the original proposal of
permanganate injection at this site, the potential for the oxidation process to mobilize certain
metals in soil makes it important that baseline and post -injection samples from at least one
monitoring well be analyzed for RCRA metals.
The proposed injection activities and related monitoring do appear to meet all regulatory
requirements in 15A NCAC 2C .0200 (Criteria and Standards Applicable to Injection Wells). As
long as the cautions and monitoring stated above are followed, the UIC Program has no objection
to the injection proceeding as proposed. A technical report summarizing the project and including
monitoring data should be submitted to the UIC Program upon completion of the injection
project. If you have any questions regarding this letter please contact me at [phone].
Sincerely,
Evan O. Kane, L.G.
Underground Injection Control Program Manager
Enclosure
cc: Randy McElveen, DWM (with enclosure)
GWS Winston-Salem Regional Office (with enclosure)
CO-UIC files
N. C. Division of Water Quality / Groundwater Section
1636 Mail Service Center Raleigh, N.C. 27699-1636 Customer Service
Phone: [phone] Fax: [phone] Internet: http://gw.ehnr.state.nc.us Fl-877-G23-G748

DEPARTMENT OF ENVIRONMENT & NATURAL RESOURCES
DIVISION OF WATER QUALITY
GROUNDWATER SECTION
1636 MAIL SERVICE CENTER
RALEIGH, NC 27699-1636
2728 CAPITAL BLVD, RALEIGH, NC 27604
FAX: [phone]
PHONE: [phone]
WEB ADDRESS: http://GW.EHNR.STATE.NC.US
TELECOPY TO: 1AA ld a
'COMPANY NAME:
FAX #:j&/5't ' TELE _/ 5; j j — jlll'5 DATE:%��b—
NO. OF PAGES INCLUDING THIS SHEET: ` C
FROM:'E'�` (� h G .� _ TELE #:
COMMENTS:--
11
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FA\SI1 E ET.%V P/6/ 13/2001

ERM-NC PC
7300 Carmel Executive Par]
August 11, 2003 suite 200
Charlotte, NC 28226
[phone]
Mr. Evan Kane �.�41-8416 (fax)
Underground Injection Control Program Manager
Groundwater Section
1636 Mail Service Center
Raleigh, NC 27699
Re: Chemical oxidation at Duracell/Gillette Site
Lexington, NC
ERM®
Dear Mr. Kane:
ERM submitted an application on February 21, 2003 to inject
permanganate into the unsaturated soils at the above referenced site as
part of a remediation project to treat chlorinated solvents. On April 10,
2003, your Section waived the permitting requirements for this project
because it is being conducted under Superfund.
Since that approval, ERM has received information that suggests it will be
much more favorable to use chemicals other than permanganate to
complete this work. We spoke with Mark Pritzl of your office about this; �-
and he said we would only need to submit the attached Non -microbial -
Risk Assessment Form as a supplement to our original application. He
also noted that the review could possibly be completed in two to three `n
weeks.
We appreciate your consideration of the attached and look forward to an C3 -�
early response. To help expedite the process, I will call you in a week to "' x
see if there are any questions that I might help answer. In the interim, if
you should have any questions, please call me at [phone].
Very truly yours,
Thomas M. Wilson, P.G.
Principal
Cc: Jack Riggenbach ERM

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolin —ment of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
April 10, 2003
Mr. Thomas M. Wilson
Environmental Resources Management
7300 Carmel Executive Park, Suite 200
Charlotte, NC 28226
Subject: Permanganate Injection at Duracell/Gillette Site
Dear Mr. Wilson:
The Underground Injection Control Group of the Groundwater Section of DWQ has reviewed
the proposed injection of sodium/potassium permanganate at the Duracell/Gillette site in
Lexington, NC, received in our office on February 21, 2003. Due to the site's status as a
Superfund site, the state's administrative permitting requirements have been waived for this
project. In light of the lack of a permit requirement, the UIC Program greatly appreciates the
opportunity to review the propo6al.
Because of the potential for the oxidation process to mobilize certain metals in soil, as well as the
potential for metal impurities in the permanganate itself, the UIC Program strongly recommends
that baseline and post -injection samples from at least one monitoring well be analyzed for RCRA
metals. Otherwise, the proposed injection activities and related monitoring appear to meet all
regulatory requirements in 15A NCAC 2C .0200 (Criteria and Standards Applicable to Injection
Wells), and the UIC Program has no objection to the proposed injection proceeding as proposed.
A technical report summarizing the project and including monitoring data should be submitted to
the UIC Program upon completion of the injection project. If you have any questions regarding
this letter please contact me at [phone].
Sincerely,
Evan O. Kane, L.G.
Underground Injection Control Program Manager
cc: Randy McElveen, DWM
Ken Mallary, US EPA
GWS Winston-Salem Regional Office
,CO-UIC files
L TAY
N_UDENR
Groundwater Section 1636 Mail Service Center Raleigh, NC 27699-1636 [phone] Customer Service
1 800 623-7748

Evan Kane
From: [e-mail]
Sent: Wednesday, April 09, 2003 12:42 PM
To: [e-mail]
Subject: Supplemental Information - Duracell - Gillette
l
Supplemental Info for Chem
Ox... In response to your request, I am transmitting the attached
contains supplemental information on the planned construction of the 2
proposed monitor wells mentioned in the UIC permit application for the
Duracell - Lexington site. Please contact me if you have any questions.
Otherwise I understand that you will complete the UIC permit application
review and provide comments in a letter to ERM. Thanks for your attention
to this matter. TW
(See attached file: Supplemental Info for Chem Ox Permit Application
4-9-03.doc)
Incoming mail is certified Virus Free.
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Version: 6.0.467 / Virus Database: 266 - Release Date: 4/1/03
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CONSTRUCTION DETAILS FOR MONITORING WELLS
The proposed monitoring wells (MP-1 and MP-2) will be drilled by the hollow -
stem auger method. A protective surface casing, grouted in place to a minimum
depth of five feet using a cement/bentonite grout, will be installed in the
borehole prior to drilling deeper in order to minimize potential problems with
carry -down of surface soils. Soil samples collected as part of the drilling
operation will be logged in the field. These data will be used to define
subsurface conditions and to locate the zone for screen placement. It is expected
that the wells be completed to a depth of about 30 feet below ground level (bgl)
based on the construction information for SR-6. The screen intervals of the wells
will be located at an approximate depth of 20 to 30 feet bgl.
Following the drilling of the borehole to its completion depth, the well screen (10
feet in length) and riser pipe will be centered in the borehole. A sand pack filter
material consisting of medium to fine silica sand (30 to 10) will be installed
through a rigid tremie pipe around the well screen to approximately two to three
feet above the well screen. A 2-foot thick bentonite seal will be placed above the
sand pack. Pelletized bentonite will be used. As the 2-foot bentonite seal is
placed on top of the filter material, organic -free, distilled water will be added
when necessary to assure that the pellets hydrate to form a tight seal. The 2-foot
bentonite seal and filter pack will be verified by tagging.
A grout seal consisting of Pure Gold bentonite will extend from the top of the
bentonite seal to the ground surface. Grouting will be completed as a continuous
operation. The grout will be pumped under pressure into the annular space
using a rigid tremie pipe placed at the top of the bentonite to assure a continuous
seal. The grout seal will be checked for settlement after approximately 24 hours
and additional grout will be added to fill any depressions.
The following materials will be used in construction of the monitoring wells:
• Screen and casing: Flush -threaded, Schedule 40, stainless steel screen and
riser pipe with 2-inch inside diameter will be used. Screen and casing will be
pre -cleaned prior to installation. The well screen will be continuously
wound with a slot width of 0.006 inch. Lockable, water -tight expansion seal
caps will be used. Wells will be locked at completion with keyed -alike locks.
The well screen and casing will be decontaminated prior to installation.
• Grout: Pure Gold Grout will be used for grouting of each monitoring well.
Pure Gold Grout is a single-phase component, organic free, high solids
bentonite clay. It will form a low permeable flexible clay seal that impedes
interaquifer fluid movement and the infiltration of surface contaminants into
the borehole. To achieve a 30% solids slurry one 50 lb. bag of powdered

grout will be added to 14 gallons of fresh water. Prior to placement, the
grout should have a mud balance density reading of approximately
10 lb/ gallon.
• Bentonite pellets: Commercially available bentonite pellets designed for
well -sealing purposes will be used.
• Filter pack: Medium to fine (30 to 10) silica sand material used in the filter
pack around the well screen and will be compatible with both the screen slot
size and aquifer materials.
• Well protection: A 6-inch minimum diameter, protective iron casing and
cover will be installed over the top of the riser to a maximum of three feet
above ground level.
• Protective pad: A concrete pad will be installed around each well.
Soil and rock cuttings generated during drilling will be collected, containerized
in DOT approved, 55-gallon drums or roll -off containers, and labeled with a
weatherproof marker showing the boring/well number and generation date.
The drums or containers will be sealed and moved to a secure area where they
will be held pending analytical results.
Following installation of the monitoring wells, the wells will be developed prior
to sampling. All field sampling methods and analytical procedures will be in
accordance with the RI/FS Field Sampling Plan (November 1995, as amended)
and the RI/ FS Quality Assurance Project Plan (November 1995, as amended).
MONITORING WELL LOCATIONS
The proposed locations for the monitoring wells, MP-1 and MP-2, were intended
to provide information on ground water quality immediately downgradient of
the chemical oxidation area and also to be outside the potential radius of
influence of the closest injection point. The proposed well locations are
approximately 20 feet downgradient of the closest injection point and should be
outside any direct influence of the chemical oxidation injection points. Existing
well SR-6, which also will be used for monitoring purposes, is located within the
actual treatment area and will provide data on ground water immediately
beneath the treatment area. The monitoring wells are planned to be sampled
following the injection process with analyses being performed, at a minimum, for
ORP, DO, color, and VOCs.

ERM NC, PC
February 14, 2003
\4393\permitting/chem ox
Mr. Evan Kane
NCDENR-DWQ
Groundwater Section
401 Oberlin Road, Suite 150
Raleigh, North Carolina 27605
Dear Mr. Kane:
7300 Carmel Executive Park Suit
200
Charlotte, NC 28226
[phone]
[phone] (fax)
N
,I
Based on the results of a Remedial Investigation/Feasibility Study
(RI/FS) and subsequent Remedial Design (RD) for the Duracell/Gillette
facility in Lexington, North Carolina, Duracell/Gillette will be
implementing a Remedial Action (RA) to address residual constituents of
concern (COCs) in soils and sediment at their site. The RI/ FS/ RD were
conducted in accordance with the requirements set forth in a Unilateral
Administrative Order (UAO) entered into between the U.S. EPA and
Duracell USA on February 8, 2001 and the Record of Decision (ROD) for
Operable Unit One dated September 30,1999. The North Carolina DENR
also has been involved throughout this process and has provided
oversight and input based on the requirements of the State of North
Carolina.
As part of the selected remedy, Duracell/Gillette will be implementing
chemical oxidation in soils above groundwater at three small areas at the
site. Therefore, we have completed the attached NCDENR Form GW-
57REM for the use of Type 5I injection wells. Detailed documentation of
the design of the overall remedial actions to be implemented at the site,
including chemical oxidation, has been provided to the U.S. EPA and the
NCDENR (Superfund Section).
Your prompt review of the enclosed information will be greatly
appreciated. If you should have any questions or comments, please
contact me at your earliest convenience.
Sincerely,
Thomas M. Wilson, P.G.
c Ken Mallary (U.S.EPA)
Randy McElveen (NCDENR)
Mike Deaton (NCDENR)
Victor Miles (Gillette)
Steve Barron (Duracell)
John M. Hines, P.G.

Evan Kane
From: Luanne Williams [[e-mail]]
Sent: Monday, October 06, 2003 10:10 AM
To: evan kane
Subject: use of hydrogen peroxide
■
Luanne.Williams.vcf
I am responding to your request regarding clarification on the hazards
associated with the injection of hydrogen peroxide for soil and
groundwater remediation. As mentioned in previous product reviews,
there is a potential explosion hazard associated with the injection of
hydrogen peroxide into contaminated soil and groundwater. In order to
reduce the explosion hazard risk, it is recommended to keep the hydrogen
peroxide concentrations at a minimum. The literature suggests that the
explosion hazard increases greatly as the hydrogen peroxide
concentrations approach 30 %. Hydrogen peroxide can be safely used by
taking necessary precautions mentioned in the product reviews. In
addition, site -specific conditions should be evaluated to guard against
explosion hazards.

9 ✓yam
North Carolina Department of Health and Human Services
Division of Public Health *Epidemiology Section
1912 Mail Service Center • Raleigh, North Carolina 27699-1912
Tel [phone] • Fax [phone]
Michael F. Easley, Governor Carmen Hooker Odom, Secretary
September 2, 2003
G
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MEMORANDUMrq
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Evan Kane TO:
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Groundwater Section
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FROM: Luanne K. Williams, Pharm.D., Toxicologist't.
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Medical Evaluation and Risk Assessment Unit
ru
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Occupational and Environmental Epidemiology Branch
x
SUBJECT: Use of Products to Remediate Soil Contaminated with Chlorinated
Solvents at the Duracell Battery Manufacturing Facility in Lexington,
North Carolina
I am writing in response to a request for a health risk evaluation regarding the use
of non -biological products to remediate soil contaminated with chlorinated solvents at the
Duracell battery manufacturing facility in Lexington, North Carolina. Based upon my
review of the information submitted, I offer the following health risk evaluation:
Some effects reported to be associated with exposure to the proposed chemicals
are as follows:
Exposure can cause severe irritation and burning of skin, eyes, nose and throat
(Meditext — Medical Management by Micromedex TOMEs Plus System CD-
ROM Database, Volume 57, 2003; New Jersey Department of Health and
Senior Services Hazardous Substance Fact Sheet TOMEs Plus System CD-
ROM Database, Volume 57, 2003).
Inhalation exposure can cause coughing, wheezing, and/or shortness of breath
including asthma -like allergy. Future exposure can cause asthma attacks with
shortness of breath, wheezing, cough, and/or chest tightness (New Jersey
Department of Health and Senior Services Hazardous Substance Fact Sheet
TOMEs Plus System CD-ROM Database, Volume 57, 2003).
Inhalation exposure can cause severe respiratory irritation and inflammation
leading to shock, coma and seizures (New Jersey Department of Health and
Senior Services Hazardous Substance Fact Sheet TOMEs Plus System CD-
ROM Database, Volume 57, 2003).
® Location: 2728 Capital Boulevard • Parker Lincoln Building • Raleigh, N.C. 27604 An Equal Opportunity Employer

2. Chemicals proposed for use may ignite combustibles such as wood, paper, oil,
etc). The chemicals proposed for use must be stored separately from hydrazine
and organic monomers since violent reactions can occur. The chemicals proposed
for use are not compatible with reducing agents; powdered metals; strong bases
such as sodium hydroxide and potassium hydroxide; alcohols; and hydrocarbon
fuels. Specifically, atone, * soil contaminant at the injection site, readily forms
explosive peroxides with one of the chemicals being proposed for use. Injection
of the proposed chemicals into the soil contaminated area is likely to result in
an explosion. Based on the information submitted, the nearest property to
the injection area that is not owned and controlled by Duracell is
approximately 350 feet west of the injection area. Measures should be taken
to prevent fires and explosions from occurring to protect workers and
nearby community. A safety plan should be developed in case there is a fire
or an explosion. The addition of a metal as being proposed can act as a
catalyst which can increase the risk of an explosion during decomposition
(Hazardous Substances Data Bank TOMES Plus System CD-ROM Database,
Volume 57, 2003).
3. Store in tightly closed containers in a cool, well -ventilated area away from moist
air and combustibles. Containers may explode when heated. Runoff may create
fire or explosion hazard. Chemicals proposed for use heat up spontaneously when
decomposing and could start fires. (New Jersey Department of Health and Senior
Services Hazardous Substance Fact Sheet TOMES Plus System CD-ROM
Database, Volume 57, 2003; Hazardous Substances Data Bank TOMES Plus
System CD-ROM Database, Volume 57, 2003).
4. If the products are released into the environment in a way that could result in a
suspension of fine solid or liquid particles (e.g., grinding, blending, vigorous
shaking or mixing), then it is imperative that proper personal protective
equipment be used. The application process should be reviewed by an industrial
hygienist to (1) ensure that the injection process is done in a safe manner, and (2)
the most appropriate personal protective equipment is used.
Persons working with this product should at least wear goggles or a face shield,
gloves, and protective clothing. Face and body protection should be used for
anticipated splashes or sprays. Again, consult with an industrial hygienist to
ensure proper protection.
6. Eating, drinking, smoking, handling contact lenses, and applying cosmetics
should never be permitted in the application area during or immediately following
application.
7. Safety controls should be in place to ensure that the check valve and the pressure
delivery systems are working properly.

8. The Material Safety Data Sheets should be followed to prevent adverse reactions
and injuries.
9. Access to the area of application should be limited to the workers applying the
product. In order to minimize exposure to unprotected individuals, measures
should be taken to prevent access to the area of application.
10. According to the information submitted, there are no wells located on the
Duracell site used for drinking, industrial processes, cooking, or agriculture. The
nearest off -site well is approximately 1,500 feet north of the injection area. This
well is reportedly owned by J&S Motors and is the source of plumbed water. The
direction of groundwater flow from the injection area is also predicted to the
north. The wells are located close to the injection area and are north of the
injection area which is where groundwater flows. Therefore, efforts should be
made to prevent contamination of this existing well or future wells that may be
located near the application area.
11. According to the information submitted, the nearest surface water drainage is an
unnamed intermittent tributary of Fritz Branch that begins approximately 400 feet
north of the injection area. The nearest blue line stream is Fritz Branch, which
begins approximately 750 feet north of the injection area. The nearest
downstream waterbody is Abbotts Creek which runs into High Rock Lake. The
surface water bodies are located close to the injection area and are north of the
injection area which is where groundwater flows. Therefore, efforts should be
made to prevent contamination of the nearby surface waterbodies.
In summary, there are serious human health concerns regarding the use of the
chemicals proposed. Safeguards should be taken to prevent fires and explosions from
occurring. Please do not hesitate to call me if you have any questions at [phone].
LW:pw
cc: Mr. Stephen H. Barron, Manager
Environmental Health and Safety
305 E US Highway 64
Lexington, North Carolina 27292
Mr. Jack Riggenback
ERM EnviroClean
300 Chastain Center Blvd
Suite 375
Kennesaw, Ga 30144

INFORMATION NEEDED TO DO RISK ASSESSMENTS FOR
PRODUCTS APPLIED TO GROUNDWATER OR SOIL
CONTAINING NO MICROORGANISMS
SEND TWO COPIES TO:
UIC PROGRAM
GROUNDWATER SECTION
NORTH CAROLINA DENR-DWQ
1636 MAIL SERVICE CENTER
RALEIGH, NC 27699-1636
TELEPHONE [phone]
Note: Please provide direct responses to each of the following items, rather than "see
attachment", etc.
Required General Information
1.
2.
3
Department of Environment and Natural Resources Groundwater Section contact person
and phone number.
Evan O. Kane, L.G.
919.73"322T—' -715 -1,16 5 fr
Current or future use of site with site contact person, address, and phone number.
Current and future use is battery manufacturing. The contact is:
Stephen H. Barron Manager Environmental Health and Safety
305 E US Highway 64
Lexington, NC 27292
336.242.6005
Contractor applying product, contact person, address, and phone number.
ERM EnviroClean
Jack Riggenbach
300 Chastain Center Blvd.
Suite 375
Kennesaw, Ga. 30144
4. Distance and likelihood of impact to public or private wells used for drinking, industrial
processes, cooling, agriculture, etc. Is area served by public water supply? Verification
must be provided by the appropriate Regional Offices of the Groundwater Section and
Public Water Supply Section.
There are no wells located on the Duracell site used for drinking, industrial
processes, cooling, agriculture, etc. As part of investigative activities, well surveys of
GW/UIC-3

the surrounding area have been conducted. The surveys have included a review of
State and local records and a door-to-door inventory. The nearest off -site well was
identified as being about 1,500 feet north of the injection area. This well is
reportedly owned by J&S Motors and is the source of plumbed water at that
location.
The nearest property to the injection area that is not owned and controlled by
Duracell is about 350 feet to the west. The direction of ground water flow from the
injection area is to the north. The nearest property to the north of the injection area
that is not owned and controlled by Duracell is about 900 feet. Potable water is
available from the City of Lexington Water Resources & Water Treatment
Department for the area in question. This can be verified by calling 336-248-2337.
Due to the large distances from the injection area to existing off -site wells or
property not under the direct control of Duracell, the likelihood of impacts to public
or private wells used for drinking, industrial processes, cooling, agriculture, etc. is
considered low. Figures showing these features were submitted with the original
UIC application.
5. General description of the contaminants if present in the soil and/or groundwater at the
site.
Chlorinated solvents including the following: Tetrachloroethene; Trichloroethene;
1,1,1-Trichloroethane; 1,1,2-Trichlorethane; 1,2-Dichloroethene; 1,1-
Dichloroethene; 1,2-Dichloroethane; 1,1-Dichloroethane; Methylene Chloride;
Carbon Tetrachloride; Acetone; and Toluene.
6. Name, approximate distance, and likelihood of impact to the nearest body of surface
water to the site.
The nearest surface water drainage is an unnamed intermittent tributary of Fritz
Branch that begins approximately 400 feet north of the injection area. The nearest
"blue line" stream is Fritz Branch, which begins approximately 750 feet north of the
injection area. The nearest downstream pooled waterbody is Abbotts Creek Arm of
Highrock Lake which is impounded about 8 miles south of the Duracell facility. The
likelihood of impacts to surface water is low since there are no water bodies near the
injection area and residual from the injection area will have to flow overland across
gently sloping grass covered land before contacting the unnamed tributary.
Exposure could only occur during high volume precipitation events when any
potential exposure would be diluted to an insignificant level. Figures showing these
features were submitted with the original UIC application.
7. Approximate distance to nearest residence(s) and workplace.
Distance to nearest residence - approximately 900 feet to the north.
G W/UIC-3

Distance to workplace - the Duracell facility, on which the injection area is located,
is the nearest workplace. The distance to the nearest off -site workplace is
approximately 500 feet southwest of the injection area (workplace is currently
abandoned). The distance from the injection area to the nearest active off -site
workplace is approximately 700 feet to the west.
Required Product/Process-Specific Information
1. Product manufacturer name, address, phone number, and contact person.
Sodium persulfate: Nick Macris, FMC Corp,1735 Market Street, Philadelphia, PA
19103. Phone [phone]
Iron-EDTA: Jim LePage, Akzo Nobel Functional Chemicals LLC,1747 Fort
Amanda Road, Lima, Ohio 45804. Phone [phone]
Hydrogen peroxide: Nick Macris, FMC Corp,1735 Market Street, Philadelphia, PA
19103. Phone [phone]
2. Identity of specific ingredients (including CAS#) and concentrations of ingredients
contained in the product and purpose of each.
Sodium persulfate CAS# 7775-27-1 100%
Iron-EDTA CAS# 15708-41-5 100% Z�
Hydrogen Peroxide CAS# 7722-84-1 70%
The purpose of each of these chemicals is to oxidize the chlorinated chemicals in the
vadose zone.
Approximate concentration of each ingredient following release into groundwater or soil.
The three chemicals will be injected into the vadose zone at the following
concentrations in water:
Sodium persulfate 7.5 weight %
Iron-EDTA 0.4 weight %
Hydrogen Peroxide 10 weight %
After injection into the 47,400 cubic feet of soil to be treated (2,155,000 kg), and
before any chemical reactions have occurred, the concentration of the above
chemicals in the soil will be approximately as follows:
Sodium persulfate 0.3 weight %
Iron-EDTA 0.02 weight % T 1
GWIUIC-3

Hydrogen Peroxide 0.07 weight %
These concentrations are based on injecting the following amounts of each chemical
into the 47,400 cubic foot treatment zone:
Sodium persulfate 15,300 pounds
Iron-EDTA 900 pounds
Hydrogen Peroxide 3,190 pounds
4. Approximate distance and direction of travel for product in groundwater, the groundwater
concentration of each ingredient at this distance, and distance from this point to the
nearest drinking water source (that is currently used for drinking purposes). These should
be reasonably accurate estimates based on the best available information and calculations
(modeling, if necessary) regarding aquifer characteristics and flowpaths at the site; where
uncertainty exists in critical aquifer parameters (e.g. effective porosity), conservative
assumptions should be made in estimating these values so that worst -case predictions of
travel distances are made.
Not applicable as these products will be applied to the v_ad_ose_zone. Also, the
treated soil will be covered with a concrete cap after treatment to prevent
infiltration of rain water in the future. As requested in the April 10, 2003 approval
1(cC letter, ground water samples will be collected before and after injection of the
chemicals. Long-term monitoring of the ground water will occur under additional
provisions of Superfund at this site.
Approximate groundwater concentration of each ingredient after pumping or recovery (if
applicable).
Not applicable as products will be applied to the vadose zone only.
b. If the product is expected to discharge to a nearby surface water, approximate
concentrations of product in the water.
No discharge will occur to surface water.
7. Documentation from authoritative technical references of specific degradation products
expected.
According to any table of standard electrode potentials tables (e.g. CRC Handbook
of Chemist and Physics' sodium nprsulfate (NaS2O8) will produce water soluble
disassociated sodium and sulfate ions upon reaction. Sodium persulfate also
degrades to oxygen, sulfate and sodium ion according to the following:
2Na2S2O8 + 2H2O —► 4Na+ + 4H+ + 4SO4-- + 02
GW/UIC-3

Reference:
http://www.fmcchemicals.com/Content/CPG/Images/AOD_Brochure Persulfate.pdf
According to Palumbo AV, Lee S.Y., and Boerman P. writing in Applied
Biochemistry and Biotechnology, (1994 Spring; 45-46:811-22), iron-EDTA (the iron
salt of EDTA) will aerobically biodegrade into ferric oxide (Fe2O3), carbon dioxide
and water.
According to any table of standard electrode potentials, hydrogen peroxide
produces water and oxygen upon reaction. According to Schumb, Satterfield, and
Wentworth (Hydrogen Peroxide, Reinhold Publishing 1955, hydrogen peroxide will
decompose into water and oxygen.
8. Documentation from authoritative technical references of expected migratory potential of
specific ingredients and degradation products in soil and groundwater.
According to the following website,(httv://www.fmcchemicals.com/Content/
CPG/Images/AOD_Brochure Persulfate.pdf) sodium persulfate (NaS2O8) is very
soluble. It will migrate in soil and groundwater as the persulfate anion. It will,
however, decompose and/or react, producing sulfate ions. The limit of solubility in
water for persulfate is 7.4 % at 25°C. Typical decomposition rates are 1-3% per
day (assuming 1% yields a half-life of around 70 days). Therefore, due to it's high
solubility residual, persulfate should not remain in the vadose zone for an extended
period of time and after one year the concentraiton would be less than 3% of the
original concentration due to natural decompositon. Since the application of the
sodium persulfate is intended to react with the chlorinated organics in the soil, it is
expected that the rate of decomposition at the Site will be much shorter than under
natural conditions. Based on these considerations, persulfate has a low to moderate
migratory potential under this application scenario.
As discussed above, iron-EDTA (the iron salt of EDTA) will degrade into ferric
oxide (Fe2O3), carbon dioxide and water. It has a low migratory potential.
According to Schumb, Satterfield, and Wentworth (Hydrogen Peroxide, Reinhold
Publishing 1955), hydrogen peroxide will rapidly decompose into water and oxygen.
It has a low migratory potential.
9. Complete description of the use of the product at the site.
The three products covered by this form are being used to oxidize the chlorinated
organic chemicals listed in item 5.
The risk assessment will be forwarded to the designated contact person for the site, consultant
applying the product, and Groundwater Section contact person.
GW/UIC-3

ERM NC PC
August 25, 2004 8000 Corporate Center Drive
Suite 200
Charlotte, NC 28226
Mr. Evan Kane [phone]
Underground Injection Control Program Manager [phone] (fax)
Groundwater Section
1636 Mail Service Center
Raleigh, NC 27699
Re: Chemical Oxidation at Duracell/Gillette Site
Lexington, NC
Dear Mr. Kane: L'' RMe
On April 10, 2003 you provided an initial concurrence letter regarding the
insitu chemical oxidation (ISCO) of soil at the Duracell Lexington, NC
facility. As you may recall, the ISCO work was part of the overall soil
remediation under Superfund at that site. As requested in your
concurrence letter, ERM is submitting this final report on the ISCO work
completed.
The chemical oxidation was conducted in a small area of the site known as
the Former Solvent Disposal Area (FSDA). The location is shown on
Figure 1. Soil in the FSDA was treated by injecting specific solutions to
chemically oxidize organic chemicals retained on the soil. Following each
round of chemical injections, soil samples were collected from selected o
locations to evaluate the effectiveness of the injections. The chemical
injection activities were conducted periodically from October 13, 2003 to
April 26, 2004.. The chemical oxidation injection and confirmatory c
sampling locations are shown on Figure 1.�
Chemical Oxidation
� G
x
The chemical oxidation injections were conducted as follows:
1. Injection 1 - 33 injection wells were installed and 7825 gallons of
10.6 weight percent sodium persulfate and 3650 gallons of 0.7
weight percent iron EDTA were injected. The iron EDTA solution
was injected first and then the sodium persulfate solution was
injected. In general, the wells were installed between 5 and 15 feet
below land surface.
2. Injection 2 - For the second injection, the same injection wells were
used and 3500 gallons of 10.6-weight percent sodium persulfate
were injected into the wells. Thereafter,1910 gallons of 8.4 weight
percent of hydrogen peroxide solution were injected.

MR. EVAN O. KANE, L.G.
AUGUST 25, 2004
PAGE 2
3. Injection 3 - Injections were completed through geoprobe rods at
four locations. Approximately 660 pounds of potassium
permanganate were injected near soil borings SB02, SB03, SB04 and
SB12. The solution was mixed at approximately 6 weight percent.
Approximately 1000 gallons of 10.4 weight percent sodium
persulfate also were injected near SB05. The chemical reaction rates
were enhanced by injecting approximately 5 million BTUs of steam
near SB05.
4. Injection 4 - Approximately 550 pounds of sodium persulfate were
injected near SB05 and SB12. The solution was injected as a slurry
in the interval of 10 to 20 feet below land surface. Approximately 4
million BTUs of steam also were added near each soil boring
location to increase the chemical reaction rates.
Soil Sampling Results
Direct push technology (Geoprobe) was used to collect soil samples in the
areas where soil was treated by chemical oxidation to remediate VOCs in
soil. One performance verification boring was installed for each
approximate 200-ft2 area. The locations of verification borings are shown
in Figure 1.
The verification samples were collected from the same depth intervals in
which VOC concentrations exceeded the remedial goals as indicated by
previous soil investigations. Because the constituents of concern are
VOCs, each discrete sample was analyzed individually. The samples were
not composited. The individual samples were analyzed for the VOCs
identified in the Record of Decision associated with the Former Solvent
Disposal Area. For each VOC of concern, soil depth and boring
combination, the average concentration was compared to the established
remedial goal set in the Record of Decision.
If the concentrations of one or more VOCs were greater than the
applicable remedial goal, additional chemical oxidation treatment was
conducted at the location and depth represented by soil samples that
exceeded the remedial goal.
After additional chemical oxidation treatment was conducted, additional
remedial goal verification samples were collected and analyzed from the
areas and depths that exceeded the established remedial goals. This

MR. EVAN O. KANE, L.G.
AUGUST 25, 2004
PAGE 3
iterative process was followed until acceptable results were achieved. No
further action was required for a location and depth interval once the
concentrations of the individual VOCs were less than the applicable
remedial goal for the protection of ground water. The final confirmation
results for the remediation of VOCs in soil are presented in Table 1.
Data collected as part of the remedial goal verification sampling in areas
remediated for VOCs were evaluated by comparing the averaged sample
results to the applicable remedial goals. The equation presented in the
Project Documents to be used to average the sample results is as follows:
x=1
Ix
X = x=n (Equation lb)
n
where:
X=mean or average value,
X=individual measurements, and
n=number of measurements.
Ground Water Sampling Results
In your concurrence letter of April 2003, you requested that baseline and
post -injection ground water samples be collected and analyzed for the
RCRA metals. ERM performed this sampling in August 2003 (before
ISCO) and again in July 2004 (after ISCO) at monitor well SR-6 located
downgradient of the ISCO area. These sampling results are summarized
in Table 2.
I trust that this report provides the information you requested. If you have
any questions, please call me at [phone].
Very truly yours,
Thomas M. Wilson, P.G.
Principal
Cc: Victor Miles, Duracell
Bill Romeo, Duracell
John Hines, ERM
Jack Riggenbach, ERM

BUILDING #4
VFS—SB-1 SB-2
SB-3
' 12 Al Al S R _ 6A
PAVEMENT
a ' 0
AI A o SB— 5
Al
SB-4 1s(AI 1
� I1
% RAVEL18
SB-6
SB — 7 AAA
SB-14 GRAVEL
S B — 9 A114 All A1112
1 SHED
B ROOF 3 9 AI 66 SB-8
117
14
g BI SB-10
16 SHED
610 ROOF
METAL SHED
I
SB-15 CI C
oc11
19
C13 SB-11
SB-13
SB-12
LEGEND
A MONITORING WELL
[j CHEMOX INJECTION POINTS PAVEMENT
Q VERIFICATION BORING
AREAS TREATED BY CHEMICAL OXIDATION N
AS SHOWN IN OU-1 REMEDIAL DESIGN
GROUND WATER FLOW DIRECTION
BUILDING
VFS - VERIFICATION FORMER SOLVENT AREA
SIB - SOIL BORING # (CONFIRMATION SAMPLE LOCATION)
EOP - EDGE OF PAVEMENT _-
CHEMICAL OXIDATION INJECTION AND
'..! - Environmental
SAMPLING LOCATIONS 1
J _�; Resources REMEDIAL ACTION REPORT
ERM Management LEXINGTON, NORTH CAROLINA

Table 1
VOC Remediation Confirmation Soil Sample Results
Duracell OU-iRemedial Action Report
Lexington, North Carolina
C
Y
E
i
O
i
Z
O
Sample
Depth (it
�•
bgs)
Remedial Goal (set) Record
--
405W
490
55"
90D
20
32600
ISO20
290
280
186000
7600
480
148000
of Decision)
'.
Final Average (1101)
13-23
231
1.1
24
4.1
1.1
71
1.1
1.1
1.7
1 2.3
2.5
1.1
136
1.1
Final Average (1102)
13-23
160
1
13
4
1
19
1
1
1
5
- 1
1
48
- 1
Final Average (1103)
8-23
195.4
1332
33.5
13.9
13.32
493.5
3022
13.32
1332
13.5
12.32
10.92
1702
1332
Final Average (1104)
13-21
29
1
2
1
1
104
1
1
1
2
1
1
6
1
final Average (B05)
8-21
497.2
12.445
87.1
11355
11.955
'_+7.5
11JW
11.86
12.64
17.03
12.435
11.955
329.9
11.1155
Final Average (1106)
13-18
288.4
2.14
- 135
20
12
12o.8
12
1.18
13.4
37.3
137.6
2.9
20
4.1
Final Average (1107)
8.13
1.1 -
1.1
954
112
1.1
106
11
1.1
72 (
13
388
5.0
4A
10
Final Average (808)
13-18
8.1
1.1
21
2.6
1.1
59 -
1.1
1.1
1.1
23 -
32
1.1
6.6
1.1
Final Average (1109)
3-8
29.02
1.09
23
142
1.09
473
1.09
1.09
2
5.2
3.47
1.09
11.4
1.09
Final Average (1110)
18.23
1129
64.4
22
42
1
17
1
1
1.8
30.8
12
1 -
114
1
Final Average (1111)
8-23
1014
25
15
45
1
212
1
1
1
25
2 1
1
27
1
Final Average (1112)
8-20
106
36
23
20
11
2473
20
11
23
271
20
23
46
20
Final Average (B13)
18-73
1661
245
28
170
3
27
4
3
4
149
5
3
169
3
Final Average(B14)
0-5
59
8
27
73
11
10
14
11
11
7
28
7
175
11
Final Average(BIS)
0-5
63
5
57 •.
71
10
6 4!
40
10
11
7 -
12
7
178
10
1661 245 954 170 13 Ift 40 13 20 271 388 2D 33D 2D MAXDNUM FINAL
RFSULT "
Notes:
All values are in units of ftilcg)
R bgs - feet below ground surface
Only the final VOC sample results are shown in this table.
Intermediate samples were used to determine where further chemical ir*dons were required, but the intermediate sample results are not included in this summary of find results.
Footnotes:
• B01 through B15 were the post -injection soil sampling locations, as shown on the Remedial Action Report Figures.
All Final Results were less than the applicable Remedial Coal.
UIC Report Tables.Wrablu 1 t of t Printed on 8252004

Table 2
Summary of RCRA Metals Analyses for Pretreatment and Post -Treatment Ground Water Samples from Well SR-6 Located Downgradient of Chemical Oxidation
Area
Duracell Facility, Lexington North Carolina
Sample ID
Monitor Well Number
Sample Date
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
DLX-SR-6
SR6
08/12/03
26 U
64.
.4 U
7.1
5.4
25
4.3 U
1.5 U
DLX-SR-6 dp
SR6
08/12/03
26 U
54.1
.4 U
6.4
5.1
1.9
4.3 U
1.5 U
DLX-SR-6
I SR6
07/15/04
1 2.1 U
1118. B
1 .2 U
1 2.5 B
1 17.5
1 .94
1 2.4 U
1 .8 U
NC Ground Water Standard (2L)
1 10
1 2,000
1 5
1 50
1 15
1 1.1
1 50
18
alifiers
J - estimated value
U - not detected
B - reported value < CRDL but > IDL
E - estimated value
dp - duplicate sample
U1C Report Tsbles.zlsTable 2 Printed on 8125/2004